debbi vigil Sun, 01/20/19 - 13:25 I am a 22 yr resident of NYC. I am against the proposed bill; regarding feeding the animals in NYC parks. While I full understand that there is a concern about attracting rats, I believe that the 'birth control' for rats program has aided in controlling the rat population. My reason for opposing this bill is simple - it will not only effect the animals; but NYC humans. New Yorkers love their animals, but not everyone has the financial or spacial means to take care of an animal in their apartment. So feeding the animals in the parks are the only way that some people are able to 'connect with nature'. Feeding the animals can be very therapudic to our mental health. If the animals leave the parks, the parks will be less enjoyable. from adaa "Specifically, pets and therapy animals can help alleviate stress, anxiety, depression, and feelings of loneliness and social isolation. Interactions with animals can help people manage their long-term mental health conditions." Please reconsider proposing this bill. The mental state of most New Yorkers is very fragile; and this ban could cause a wave of suicide and increase in mentally ill homelessness.

Katherine Mulholland Sun, 01/20/19 - 16:27 I strongly encourage NYC parks to implement this rule against feeding animals in parks and to ensure that it include a prohibition against feeding cats. Habituating wildlife to humans through feeding often ends badly for wildlife. In addition, human-provided food rarely meets the nutritional requirements of wildlife. In particular, feeding waterfowl poor diets (bread, popcorn, etc) can cause wing deformities and it pollutes the water. Feeding free-roaming cats should be prohibited everywhere, but especially in parks. Feeding cats causes them to congregate in abnormally high densities, increases their breeding success, and simply makes them better able to chase down and kill our native birds and wildlife. The parks department should take steps to remove free-roaming cats from public parks either for adoption to indoor homes or euthanasia.

Rebekah Creshkoff Tue, 01/22/19 - 13:11 I don’t see any mention of cats. Are they among the “wildlife” that park patrons will be barred from feeding? I certainly hope so. Domestic cats are not native to the Americas, and their presence in natural areas is well-documented to have a significant and negative impact on bird populations. I strongly urge you to specifically ban 1) the feeding of cats, and 2) feral cat colonies in this rule.

Matthew Wills Wed, 01/23/19 - 16:38 I agree with these rules. As a naturalist and educator, I visit parks and other green areas (state land, cemeteries, botanical gardens) around the city regularly (in Brooklyn, Manhattan, Bronx, & Staten Island). As much as well-meaning people like the idea of feeding wildlife, it's generally a bad idea. Feeding junk food to waterfowl and encouraging invasive feral cat populations with feeding stations are enormous problems. Unfortunately, tradition, ignorance, and, in the case of fans of feral cats, something akin to fanaticism, continue. So, YES to regulations that cover "feeding all animals" and yes to ENFORCEMENT of these regulations in the future.

Ryan Mandelbaum Thu, 01/24/19 - 14:00 I strongly support this rule and its intention. I am resident of the city who cares deeply about its ecology and its wildlife and recognize the detrimental effects that feeding waterfowl, feral cats, raccoons, and squirrels in the park can have on widlife as a whole. However, I would also request an exception to be made for approved, maintained bird feeding stations in locations such as Central Park and Prospect Park during the winter. Bird watching can draw as many 500 birders to Central Park on a single day (see link below), with much activity surrounding the feeders. Thanks again for proposing this important rule. I appreciate it and its intention.

Matthew Combs Thu, 01/24/19 - 16:01 I strongly support the proposed rule. There are many opportunities to interact with and appreciate wildlife in NYC that do not involve direct feeding. Wildlife in NYC do not need supplemental food sources and do not need to be "taken care of" by those that engage in regular or sporadic feeding. As a trained rodentologist I recognize that anthropogenic food resources provided by animal feeding can and do contribute to increased local rat populations. Feeding of wildlife almost always leads to excess and uneaten food items that can be easily foraged by rats. Rats also learn from their environments, so may be more likely to visit and inhabit areas where feeding occurs, thus increasing the potential for zoonotic transmission of disease. This rule is long overdue and will help create a more sustainable relationship between citizens and urban wildlife.

Jonathan Cohen Fri, 01/25/19 - 10:31 As a researcher that has been studying saltmarsh and seaside sparrows in New York City Parks since 2012, I strongly support the proposed rule. Both sparrow species are restricted to the salt marshes of the United States, and the saltmarsh sparrow in particular nests only between Virginia and Maine. The saltmarsh sparrow is in grave danger of extinction due to loss of habitat. Non-native predators such as rats increase their peril greatly in the few urban areas where the sparrow has managed to hold on, which includes New York City Parks properties. Reducing wildlife feeding in NYC Parks will help reduce predator populations and improve the chances for these and other imperiled native wildlife.

Kay Lindstrom Mon, 01/28/19 - 11:41 I am against the proposed ban on feeding wildlife. Please see the file I have uploaded which contains facts about animals and disease.

Alex Cook Tue, 01/29/19 - 11:01 As a graduate student at a New York State university researching 2 species of imperiled birds which rely on the fragile natural areas of NYC, I strongly support this proposed rule. Banning the feeding of animals in parks, most of which are non-native species, will have rippling positive affects on the native wildlife of NYC. Species like rats, raccoons and cats, all of which benefit from feeding by humans, also act as predators, causing harm to native wildlife populations. This proposed rule has the potential to reduce the negative affects these species have on native NYC wildlife.

Hayley Horbatowska Tue, 01/29/19 - 19:54 In theory I'm supportive of this change. To avoid the rats yes and also to stop the wildlife from becoming too tame. As sadly there are always people out there who will then cause injury to them. But If this rule passes, could something be included to allow people or rescue groups to help the domestic birds that are dumped there. There must be something the rangers can do to aid in the rescue of these animals, which would maybe help reduce people trying to feed them. I've seen a rise in domestic birds dumped in the park lately, so there should also be a rule in place to deal with this. And if there are people out there who are willing to help, seems like a win win situation.

Kevin Sisco Thu, 01/31/19 - 17:21 I am long term resident of the Upper West Side (UWS) and a member of the UWS Neighborhood Naturalists, a group of like minded people who monitor and advocate for biodiversity within our community. We strive to help educate and inform our neighbors about biodiversity and communicate Neighborhood biodiversity concerns to local government. I have read the proposed new park rules which, if enacted, would ban the feeding of squirrels and birds within New York City parks. I have read the goals of the new rules and for the most part suppprt them. I do, however, have a strong concern about the new rules and would like to express that concern here. As an avid bird watcher, I enjoy bird watching in Central Park, as well as many of the other city parks. I would like to advocate that the bird feeders set up in Evodia Field in Central Park, as well as the bird feeders set up in other New York City parks, be permitted to remain even if an overall ban on feeding birds is enacted. The presence of the bird feeders in Central Park, long standing, and sanctioned by the Parks Department, provide important functions within our community. The feeders provide food for birds, largely during winter months, when the supply of natural food is scarce. The bird feeders are enjoyed by hundreds of park users (not just avid bird watchers) who enjoy watching the birds. Many of these people spend the better part of the day there watching the birds. Further, the bird feeders are used by local schools and teachers who bring their students there to teach the students abour birds and the overall environment. The bird feeders are tended and financed by local bird watchers who provide correct, healthy food for the birds. The bird feeders are located in a confined area and have not resulted in an increase in the population of rats or resulted in an increase burden on park employees. Considering all of the positives that the bird feeders provide, I strongly urge that the bird feeders in Central Park, as well as those in other NYC parks, be permitted to remain if the proposed new park rules are enacted. Respectfully submitted, Kevin Sisco UWS Neighborhood Naturalist

Nancy Tognan Fri, 02/8/19 - 11:33 From: Nancy Tognan, Vice President, Queens County Bird Club I am opposed to the proposed rule as it pertains to feeding seeds, suet, and fruit to birds. Feeding of birds is an enjoyable activity that I and many people engage in at home. It is nice to see woodland birds within twenty feet of my window. However, many New Yorkers do not have a backyard and enjoy feeding the birds in the parks. The choice of feeding materials matters. Bread is not good for birds, but seeds and fruit are. I would encourage a public education campaign to have people provide good food to birds and refrain from using bread. I think most people would not wish to harm birds or adversely affect the water quality in our ponds. Some people have set up suet and seed feeders that are healthful and do not create a mess. Both the National Audubon Society and the American Bird Conservancy have expressed views that feeding seed to birds is not harmful. Feeders are mentioned in the American Birding Association’s code of ethics. Re: rats. You need to focus on those parks in which rats are a problem, not every part of every park in New York City. Again, you need a public education campaign to encourage people to clean up their food garbage, until you are able to trap and remove the rats. It would probably be helpful for NYC Parks to empty the garbage cans at such sites more frequently. A sledgehammer will certainly kill a fly. But is it the tool of choice to remove a fly from your home’s plaster walls? Like the sledgehammer, your law against all bird feeding is too broad, overly damaging, and not the correct tool to use. Thank you for your attention in this matter.

Laura FRIEDMAN Thu, 02/14/19 - 14:47 I am in favor of this new regulation. I spend quite a bit of time in that park and it pains me to see the animals fed food that is meant for humans and it not good for them. It hurts our ecosystem, it hurts the animals and it offers a bounty to the rats living in the park and the boat basin. Please adopt this new rule.

Anna Dove Sat, 02/16/19 - 22:49 I am against the proposed legislature which would make feeding wildlife in parks against the law. You demand that we conform to a society which is for the most part unsympathetic and uncaring to creatures who share the Planet with us. However, my First Amendment constitutional right as an American citizen gives me the right to practice a religion of my choice. My religion of compassion and kindness tells me to share my food with the hungry. As a senior person, I do not want to spend my last years on Earth denying my true self or who I am. I want to be able to give a hungry squirrel a nut; I want to be able to do so without incurring fines or admonishments. On the other hand, food thrown on the ground with the intention that an animal will find it is careless and irresponsible. If someone desires to feed an animal, it should be done when the animal is present, and seen to that all food is consumed with no food left on the ground before departing the area. Parks should be a place where we can relax, especially for those who cannot escape the sterile City of concrete and clay. Parks are one of the few places where it's possible to enjoy animals and birds, and if that enjoyment extends to giving a few hungry birds a few seeds, we should be able to do so. After all, some of us are trying to improve the World and make it a better place for all, not just for us.

Lisa Scheppke Mon, 02/18/19 - 22:48 I am opposed to the proposed new rule as well as the decision to hold the hearing in Harlem. I doubt many people that oppose this rule would feel safe enough to attend this hearing because Harlem has a reputation as a dangerous place. I am opposed to the proposed rule because enacting it would negatively affect the many bird watchers and nature lovers that visit bird feeding stations in NYC parks. Many bird watchers are elderly and/or have physical disabilities and these park users will be put at a distinct disadvantage since the feeding stations allow these individuals to see birds that they may not ordinarily be able to see due to difficulties accessing other areas of the parks. These feeding stations contain healthy bird food like seeds, nuts, and suet and they are maintained by experienced bird clubs and individuals who know how to avoid the spreading of disease among the birds that utilize the feeding stations. These stations allow park users to observe the birds that congregate there during the months when natural food may be scarce and they may mean the difference between life and death to certain birds, especially during extreme winter weather conditions. These feeding stations also provide educational opportunities since observers also include children and families. I do not believe that these stations increase the rat populations in NYC Parks since I have visited feeders many times and have never seen a rat in the vicinity of these stations. While I understand the need to stop people from the unhealthy and potentially dangerous feeding of certain wildlife such as feeding bread to waterfowl or the feeding of raccoons, those situations should not be equated to the bird feeding stations. The birds that use these stations do not pose any danger to humans. Please do not enact this rule as written. Please rewrite the rule to focus specifically on other forms of unhealthy feeding and make sure to include language in the proposed rule that allows these beneficial feeding stations to continue to exist.

DAVID BARRETT Wed, 02/20/19 - 21:05 I am opposed to this proposed rule as it regards the feeding of appropriate foods -- such as grains, seeds, vegetables, fruit, suet, etc. -- to birds. As others have noted, feeding birds these good foods is not known to be harmful, and major birding organizations such as the National Audubon Society encourage people to supply these foods in bird feeders: At times, generally during winter when food is hard to find, certain bird species will come right to your hand to take seeds. Hand-feeding this way brings joy and a connection with nature to some people, and likely also benefits the birds. Toss seeds, grains, or vegetables to ducks in winter and they will snatch them up quickly, leaving no waste. I walk the parks of Manhattan nearly every day in the course of my birding, and I see no correlation between the extremely limited and geographically-restricted bird feeding that goes on and the presence of rats. Rats abound in many areas where no bird feeding takes place. To the extent that NYC parks have a rat problem, it is from open trash receptacles and food litter, and an established population that continues to reproduce, not from people responsibly feeding birds.

Lily Roccosalvo Thu, 02/21/19 - 10:19 I strongly oppose this rule, wild life and specially wild birds are an asset to bare concrete jungles as NYC. Wildlife is often the only contact that senior citizens and children have with nature. Human quality of life will be strongly affected if they are deprived of these interactions. Please don't stop caring people from interacting with wildlife in the city. Thank you for you attention

Catherine Barron Thu, 02/21/19 - 10:52 I support the proposed rule on prohibiting the feeding of wildlife in NYC packs. Please consider exempting feeding stations used for education or tourist attractions. Examples are the feeders at Blue Heron Park, Staten Island and Central Park. I suggest that such feeders be permitted annually and have a designated care taker. I request that the rule be enforced and that there be signage with penalties posted. It is extremely concerning when one finds food put out for white-tail deer that are very close to streets with heavy traffic. An example is Clove Lakes Park, Staten Island. Thank you.

Patty Adjamine Fri, 02/22/19 - 0:34 I strongly oppose the proposed feeding ban of wildlife in NYC parks as it unfairly targets and scapegoats the elderly, the poor, the disabled and children -- the people usually feeding wildlife in the parks. To threaten with fines and arrest, the most vulnerable of our society for doing something that people have been doing hundreds of years ( "feeding ducks") is shameful and despicable -- almost as despicable as allowing suffering wildlife to starve to death on an iced-over Reservoir as what occurred in the winters of 2014 and 2015 in Central Park. This proposal needs to be defeated in no uncertain terms. Patty Adjamine

nicki gondell Fri, 02/22/19 - 9:25 Parks People, I strenuously object to the proposed rule changes prohibiting feeding 'wildlife' in the parks. At a time when human activity is causing so much damage to our nation's bird and wildlife populations, New Yorkers are to be applauded for caring so lovingly for our feathered friends and neighbors. Feeding the birds is a compassionate act which brings so much joy and reminds us that we are all part of one interconnected ecosystem. A handful of birdseed is not a scapegoat for too many rats -- for that you have to look to the thousands of garbage bags and cans on every street and corner on this overcrowded rock we all share. This recent piece in the Times explains exactly how dire is the outlook for our backyard birds. I beg you to do the humane thing and allow us bird fanciers to get on with it, for our sake and for that of the birds. Sincerely, Nicki Gondell

nicki gondell Fri, 02/22/19 - 9:25 Parks People, I strenuously object to the proposed rule changes prohibiting feeding 'wildlife' in the parks. At a time when human activity is causing so much damage to our nation's bird and wildlife populations, New Yorkers are to be applauded for caring so lovingly for our feathered friends and neighbors. Feeding the birds is a compassionate act which brings so much joy and reminds us that we are all part of one interconnected ecosystem. A handful of birdseed is not a scapegoat for too many rats -- for that you have to look to the thousands of garbage bags and cans on every street and corner on this overcrowded rock we all share. This recent piece in the Times explains exactly how dire is the outlook for our backyard birds. I beg you to do the humane thing and allow us bird fanciers to get on with it, for our sake and for that of the birds. Sincerely, Nicki Gondell

Kathleen Scheppke Fri, 02/22/19 - 10:51 This new potential rule is a bad idea if there are no exceptions allowed to the rule. People have been enjoying the feeding of animals in parks for eons without any major disasters occurring. Please do not infringe on the rights of New Yorkers to engage in an age old tradition. There are many more important problems in New York City that the city should be dealing with instead.

Laura Taylor Fri, 02/22/19 - 14:17 I am opposed to this proposed rule. It is the joy and livelihood of many New Yorkers to feed birds and other wildlife in the parks. This is a timeless New York tradition that people have enjoyed for many years. Mainly the elderly, disabled, and families with children are mostly seen feeding the birds and other wildlife. It is an unfair discrimination to target them in this proposed rule. Myself as a frequent visitor to Central Park have witnessed and documented waterfowl which died of starvation in the past during very cold winters we have had. The suffering of these animals indured was heartbreaking to see. In the winter months when food is scarce you can clearly see ducks and geese in anguish from hunger. Currenly there is no Plant Life at the Central Park resevoir, it has been chopped down for 1 year now. Waterfowl relied on this as their source of food. They have none now. I have never once seen any wildlife in Central Park or any NYC park become aggressive because of being fed or from being in close contact with humans, I have seen the exact opposite- Birds, geese and other wildlife all display calmness, friendliness when being fed, they will even eat out of your hand with no sign of agression. I have never once in all my years visiting Central park seen rats come out after myself or other wildlife have been fed in the park. When feeding birds and other wildlife the food is eaten up within seconds with nothing remaining. The only time I see food laying around in Central Park is by people who liter, especially during the many events, concerts in the park. I have seen rats around this food. Perhaps there should be a rule proposed on litering in the Parks. In the Summer some Parks around the city especially those with barbeques look like garbage dumps with garbage and food left all around. Also I feel Park Rangers need to be trained properly and enoforced on rescuing wildlife in the parks. In Central Park there was a pregnant dumped stray cat that was roaming for months. Conservancy was alerted by many people. Rangers did not rescue this cat. Cat was a friendly stray that would approach people to be pet. It suffered and all its newborn kittens died in the park. There are so many dire issues in NYC that need attention. Not a ban on feeding wildlife with a jail sentence for the elderly and children.

Eli Cohen Fri, 02/22/19 - 17:00 Please see attached a comment from the New York City Bar Association's Animal Law Committee opposing the proposed rules. Thank you for your attention.

Will Papp Fri, 02/22/19 - 17:22 * IT IS A WASTE OF TIME AND MONEY ON MAKING A RULE AND NOT ENFORCING IT. IN CENTRAL PARK THERE IS A RULE THAT DOGS SHOULD BE ON A LEASH BY 9:00 AM. NOT ONCE HAVE I SEEN ANYONE PENALIZED FOR DISOBEYING THIS RULE. THE CENTRAL PARK CONSERVANCY SPENDS LOTS OF MONEY PLANTING THE GRASS WHILE I WATCH IT BEING TORN APART FROM DOGS OVERUSE OF IT. LET ME HERE HOW YOU PLAN TO ENFORCE THIS RULE? • RATS ARE ALL OVER THE CITY. WILL THE NEXT RULE BE NO EATING ON THE STREETS? MAYBE THE NEXT RULE WILL BE NO VENDORS ON THE STREETS? MAYBE THE NEXT RULE WILL BE NO TRASH BINS ON THE STREETS. (WHICH IS A MAJOR FOOD SOURCE FOR RATS) • In addition I am opposed to this proposed rule as it regards the feeding birds appropriate foods such as grains, seeds, vegetables, fruit, suet, etc. to birds in designated areas where there are feeders. As others have noted, feeding birds these good foods is not known to be harmful, and major birding organizations such as the National Audubon Society encourage people to supply these foods in bird feeders: HISTORICALLY, feeders have always been part of the Parks. Offering joy, amazement, education and socialization to thousands of people. HISTORY: “By 1899 Anne A. Crolius had set up the first "official" feeding station in the Ramble ( CENTRAL PARK) for Black-capped Chickadees and others.” THANK YOU

Joan Harrison Sat, 02/23/19 - 14:13 I strongly object to the proposed rule to outlaw the feeding of animals in city parks, who bring so much joy to so many, and whose lives are all too often disrupted or cut short by the folly of humans. There are said to be between 1 and 3 million pigeons in NYC, about a third of whom die annually of natural causes, many of starvation. Though most endure great pain and grief at human hands, some throw themselves under onrushing vehicles when their hunger is beyond bearing. Pigeons, sparrows, and starlings may be seen daily struggling to scrape molecules of food from sidewalks and gutters. Desperation may even drive them to eat human vomit. When adequate food and water are supplied at regular intervals, pigeons will live into their twenties, sometimes beyond. Without that they usually die between 3 and 5 years of age. They need to be fed. The pigeon is among the most misunderstood and misperceived of nonhuman creatures. I am privileged to be acquainted with several flocks , one of which I've fed and studied for over a decade. I gave the birds names and taught them to fly into my hand when called. As much as I've taught them, however, they've taught me a great deal more, some of which I've not found even in the recent literature on the minds and emotional lives of birds, of which there is an abundance. The Parks Department ought to familiarize itself with that literature before proposing a rule that would be tantamount to a death sentence for such exceptional beings. A good book to begin with: The Genius of Birds, by J. Ackerman. The Parks workers water, feed, and prune plants throughout the city. What about hiring others to provide nourishment for birds and squirrels? That would guarantee a supply of seeds and nuts rather than bread or other non-nourishing foods likely to attract other hungry creatures. To feed another is to nourish one's own soul. Some who feed pigeons and squirrels regard them as angels from God sent to deliver them from their isolation. The Parks rule would hurt such people. European cities construct pigeon lofts atop buildings—as in antiquity—in which flocks are fed and housed at the city's expense, with the birds paying an egg now and then to keep their numbers down. Suffering creatures are as upsetting to witness as happy creatures are a joy and the look of city pigeons varies greatly. Those I fed in Harlem were emaciated, tired, sooty, and mutilated at the feet by thread or other debris. Those at Columbia U. seemed clean, healthy, and alert. I reject the Parks Department’s proposal.

Erwin Scheppke Sat, 02/23/19 - 15:37 I am in opposition to the proposed rule since I am someone who loves to watch and photographed birds at bird feeders in the winter. By the way if the NYC Department of parks and recreation institutes this rule, then the sparse winter visitation that parks now have will likely drop even more since many birdwatchers visit parks in the winter specifically to visit feeders. Perhaps this will bring about a decrease in the parks dept. budget so maybe the parks dept. should leave well enough alone.

T. H. Luhrmann Sun, 02/24/19 - 15:43 I oppose this proposal to amend § 1-04(g) of Chapter 1 of Title 56 of the Rules of the City of New York. If this rule is enacted or rather "amended," I believe there will be no widespread or effective enforcement of it. Enforcement will be limited, haphazard, and clumsy for the simple reason that the NYC Parks Department doesn't have adequate staff, resources, or funding to properly enforce it. If this rule is amended, there will undoubtedly be well-meaning, innocent, and unsuspecting citizens who will be ticketed for feeding sparrows and pigeons in the city parks. The NYC Parks Department will feel compelled to set an example as a deterrent, and it does have the resources and authority to do so. However, if these targeted citizens refuse to give the apprehending park rangers(s) their names and addresses (or they provide false names and addresses), they cannot be let off with just a ticket and a fine and will either be jailed or be at risk of being jailed. The birds, squirrels, racoon, mice, and skunks that inhabit our parks will derive no significant benefit as a result of their incarceration, and there will be no discernible effect on the rat population of this city or its parks. Last time I checked, appetizing edible garbage was piled up outside the back entrances of the residential buildings abutting major city parks. Last time I checked, there was appetizing garbage overflowing the trash cans in the parks themselves or it was strewn across their lawns. Last time I checked, the inhabitants of the homeless encampments hidden in overgrown areas of major city parks were not recycling or properly disposing wet, edible garbage. Even a widespread, humane, and effective enforcement of this proposed amended rule (a level of enforcement that is not likely to occur) would have little discernible impact on the rat population of this city and its parks. Controlling the rat population should perhaps be somewhere on the list of reasons put forward in this proposal to amend § 1-04(g) of Chapter 1 of Title 56 of the Rules of the City of New York. It should not, however, be at the top of the list, which is where it has (inadvertently?) been placed. The public parks of New York City are, for better or for worse, public parks.They are not (not yet) wildlife sanctuaries, with access limited to licensed professionals and supervised groups. Maybe that day will come, maybe that day should come. In the meantime, in the city in which we live, I oppose this proposal to amend § 1-04(g) of Chapter 1 of Title 56 of the Rules of the City of New York for the reasons stated above.

Rose Glass Mon, 02/25/19 - 11:20 I am strongly opposed to the proposed rule that would prohibit the feeding of wildlife in the City Parks. It is unfair and would target the most vulnerable New Yorkers. The people who are most often spotted feeding the wildlife in our city parks are our senior citizens and disabled. Senior citizens are often living the New York nightmare: alone and friendless in a city where they have outlived their friends and are scorned by the young just for being “old”. They visit the park and their lives are transformed through a simple kindness toward a squirrel or bird. They have no intent on harming any animal or any person. Others suffer depression but find relief in the therapy provided by feeding the wildlife in the park. Research has proven that such interaction with nature promotes psychological restoration, improved mood and reduced stress and anxiety. The proposed ban would punish the elderly, the depressed and disabled for performing an act of kindness. It is despicable to even propose to fine and/or jail defenseless, compassionate New York citizens, lowering the quality of life for them and those who have to witness these warmhearted people being chastised and penalized. As for the wildlife being harmed by this, it has been my observation that most of the seniors and disabled have educated themselves so that they are not feeding foods that harm the wildlife. Instead, it’s the people that litter by dropping food on the ground or lazily leaving food on the benches who are inadvertently providing harmful food substances to the wildlife. The supporters of this ban complain that feeding the wildlife is feeding the rat population while they ignore mentioning the people who consistently fail to put the remainder of their unfinished lunches or dinners in the park trash bins. This food is not just harmful to the squirrels and birds, but is the real food that ends up feeding the rats. Although there is an established rule against littering in the city/parks, customers of a popular outside fast food place in Madison Square Park seem to be exempt from it. . A restaurant like this has such autocracy in the park that even though it is known to be the major contributor to the expansion of the rat population, the park chooses to look the other way. In addition, the restaurant’s expansive, uncovered, open-air dumpsters on the nearby street corner act as a buffet for rats in the park. Yet, under the proposed rule, poor senior citizens would be fined while the mother ship of this wealthy outdoor eatery chain would continue making its fortune. Instead of discriminating against its most vulnerable citizens, why doesn’t the park/city choose instead to educate the public about the wildlife? Why doesn’t the city encourage people to discard their litter/food remains properly? These are the actions of a forward thinking compassionate society that I would hope we, as New Yorkers, are. THIS RULE SHOULD NOT BE ADOPTED.

Leah Juneau Mon, 02/25/19 - 16:04 I Oppose the adoption of this proposed rule. I always thought that urban parks were for the benefit of the public and not just for the governing elite board members of the park conservancies. But more and more, the parks are being tailored to appeal to only those patrons who gift the public parks with large donations. These are the people who are setting the rules. They are the ones that say what goes because it is their money that is doing the talking! So if they don’t want the squirrels in the park, they say that the wildlife exhibits aggressive behavior from being fed by visitors. They say that feeding them deters them from seeking the natural foods—like insects and plants—with nutrients they need. They do NOT say that the trees in some parks no longer support the food needs of the squirrels. They do NOT say that parks, like Madison Square Park, for example, seek(s) to be a “designer” park with eyes on establishing itself as a world class arboretum by diversifying the tree species in the park. While there is nothing wrong with this on an aesthetic level, many of the trees that are being introduced to the park will provide seasonal interest to visitors but not provide the proper habitat for the squirrels that reside in the park. (Unlike Riverside Park where there are still plenty of natural oak trees that supply a normal habitat for the squirrels that reside there). The people that have proposed this rule demonstrate a blatant disregard towards the importance and beauty of the wildlife that inhabit these man-made “ecosystems (urban NYC Parks). The aggressive over use of rat poison in Madison Square Park is poisoning all their wildlife. It is only a matter of time before even the supposedly protected hawks living in the Park eats one of the many poisoned squirrels, birds or rats and ends up poisoned also. Unfortunately, it seems that those proposing this rule do not respect another living life form that doesn’t directly benefit them - If they can’t eat it, own it or bank off of it, it is of no value to them! The result: punishing the wildlife and punishing the people that care about the wildlife in the park. Even the sad fact that they would be punishing our elderly does not seem to bother them. Like the wildlife in the park, these unfortunates are an inconvenience and it is better to fine them and rid the parks of them once and for all. How is this fair?

Bill Weisman Tue, 02/26/19 - 1:04 I am a lifelong resident of NYC and enjoy visiting the parks for exercise, viewing the wildlife, and as a respite from the concrete jungle all around us. I am opposed to the proposal as it is written and I will offer some suggestions as a way to help remedy this situation. I am aware of the harmful effects of feeding improper food to the wildlife (especially birds and ducks) and the potential of the food to attract rodents. My idea would be to install feeding stations around popular areas where most of the feeding takes place ( In Central Park- around the ponds, lake, pool and the Meer). These feeding stations could have vending machines that contain proper food for the wildlife and for a small fee people could buy the proper food that is healthful and nutritious. People love to feed wildlife and I think it brings joy and solace for the people that enjoy this type of activity. I don't think this food will attract rodents as the fee will hopefully discourage the over feeding of the wildlife and the wildlife will eat up all of the food that is fed to them. The fees could also help to hire extra staff that would make sure these areas are kept clean and do not attract any rodents due to extra food that may accumulate. Good educational signage around these feeding stations about feeding wildlife a proper diet would also be helpful. If you look at the feeding stations that are properly maintained by the birding organizations in many of the NYC parks, you do not see any rodents around these areas due to the care and vigilance of the many volunteers that take care of these feeding stations properly. I also think that feeding the wildlife is not where the rodent problem is coming from. The rodents are attracted to the garbage that is overflowing around the garbage cans and from the random tossing of garbage on the ground throughout the parks. A better focus would be on enforcing no littering and emptying the garbage cans more frequently so garbage doesn't accumulate. Possibly the fees from the feeding stations could help to defray the cost for the extra staff needed to empty the garbage cans more frequently and extra enforcement of the no littering laws. An additional way to help control the the rodent and pigeon population would be to make the parks more 'Raptor & Owl friendly'. Raptor friendly could encompass making sure there is no rodenticide used in any of the parks at any time of the year - not just during breeding season. Also monitoring of any raptor nesting sites (which is currently being done) to make sure nest areas are protected and not disturbed. I hope some of these ideas would help to redirect the focus of the proposal and help to contribute to the enjoyment of the parks for all of the local people and visitors to our public parks.

Elizabeth Sorrell Tue, 02/26/19 - 12:25 I support this rule as it is in the best interest of native wildlife and the habitat we all share in NYC. Feeding of animals can be harmful to the animals (as most casual feeders do not have knowledge of and/or access to appropriate food sources), increases the presence of invasive animals (which has a negative effect on native wildlife), disease outbreaks, and aggressive animals (which then get euthanized). I support managed bird feed stations, which is rule will not negatively effect.

Jessica Hope Tue, 02/26/19 - 12:44 I support the goals of the proposed rule to the extent it protects wildlife. However, an exception to the rule is absolutely necessary to allow animal rescuers and rehabilitators to assist injured wildlife and domestic animals. In my experience, wild birds are much more likely to sustain life threatening injuries from fishing line and hooks than from park goers feeding inappropriate foods. The issue I most frequently encounter in NYC parks is waterfowl and other animals becoming tangled in fishing line and impaled with fishing hooks. Food is absolutely vital in order to lure birds close enough to catch them so that they can be untangled or transferred to a veterinarian or rehabilitation clinic. When released, most birds (especially those who have been kept in captivity for many weeks or even months during their rehab) need a “soft release,” which requires feeding to support the bird after release as they reacclimate to life outdoors. Another common issue in NYC parks is the dumping of domesticated animals and “exotic pets.” These include the hundreds of domestic ducks dumped each year. These birds are completely different than wild birds, having been modified and bred for meat or egg production. They have large bodies and small wings, which do not allow them to fly. They have more than twice the caloric requirements as wild ducks and winter is especially perilous for these ducks when the ponds freeze and any naturally occurring food sources dry up. Rescuers keep these birds alive by feeding them species appropriate foods (that are healthy for wildlife) until they can be caught and placed in homes. Dumped domesticated ducks only survive because concerned residents feed them. It is important to note that it can take months or even years of feeding and building trust before domestic ducks can be rescued. Some rescues require kayaks, which is not permitted by the Parks Department while parts of the ponds are frozen. These ducks need to be fed to keep them alive until they can be rescued. Unfortunately, the Parks Department has been ineffective in preventing or cleaning up litter that injures wildlife, does not prevent the dumping of animals, and 3) does not rescue injured wildlife or dumped domestics. This is despite being regularly contacted about refuse in the parks that can harm wildlife, as well as about sick or injured animals. Should the Park Rangers respond at all, they are routinely incorrect in their evaluation of the condition of the animal or cannot catch the animal needing help due to lack of training and experience. Because the Parks Department neither prevents situations that lead to animals needing help, nor provides assistance when they do, animal rescuers and rehabilitators must take it upon themselves to both (1) rescue dumped or injured animals from the parks and (2) support the dumped animals who cannot be captured or until they can be rescued, (3) support recently released wildlife.

Johanna Clearfield Tue, 02/26/19 - 13:00 The use of "rat management" is the most popular justification sited by Parks and other organizations when the complex and critical issue of wildlife care and balance is truly at stake. Very recently, the cancer-causing chemical "Round-up" has been re-introduced into "weed management" in Prospect and other NYC parks simply because this reduces the expenditure previously allocated to park workers. Those workers manually weeded and rid the park of sprawling or unwanted growth with landscaping techniques that require compensation. Using "rat management" as a scape goat for reckless and gross negligence in the care and management of our park's amazing wildlife - is more of the same. Prospect Park is blessed with a variety of amazing wildlife including ducks, geese, possums, raccoons and an array of migratory and domestic smaller birds. While we continue to pour hazardous waste into the air and water, these parks provide a tiny refuge. Instead of increasingly converting park spaces that host wildlife into for-profit-event arenas that invite enormous foot traffic and threaten the wildlife in those areas (case-in-point the Lollapalooza staged in the same area where migratory birds were just returning) -- these spaces need to be protected and cared for. Instead of massive ear-splitting rock concerts, an effort could be made to provide wildlife learning areas for children and teens as well as protect our wildlife for future generations. In addition, fines or punishment for feeding wildlife should be replaced with signs that educate the public as to what can be and cannot be fed to wildlife. Often ignorance is the cause for littering or leaving food that later ends up being scavenged by rats. Punishing children for feeding dried corn to ducks or peanuts to squirrels creates a toxic divide between children who desire to interact with wildlife and children who are isolated and ignorant of that interaction. Children and teens who interact with wildlife have proven to grow up into adults who seek careers or have values that concern the wellbeing of our planet. It creates an extremely hostile park environment if/when children -- and adults -- are being punished for an age-old tradition of "feeding the birds" or the squirrels. A tradition that has long brought delight and humane understanding between human beings and our friends, the wildlife in our midst. @johannaclear

Tiger Buchman Tue, 02/26/19 - 13:25 As a trained and working Ethologist, I can agree with the reasoning of the proposed rule, but as a rescuer I understand the limitations and ask that the Parks department modify those rules for those who work with wildlife and rescues. There are already many city programs in place that certify both domestic and wildlife rescuers. The Parks department does not have to reinvent the wheel. Most rescuers are only concerned with the release of domestic animals or injured wildlife. I can also understand the difficulty this may cause to Parks Department Personnel, having to distinguish people from the general public and those trained as rehabilitators and rescuers, but these animals are not in peril due to their own fault, and at least a little thought must be given to their best wellbeing as well.

David Geller Tue, 02/26/19 - 13:41 I vehemently oppose the adoption of this rule. Banning the feeding of park wildlife would be a big mistake! It does not fit with the purpose of the NYC Parks being green spaces/an oasis in a city of paved streets and cement buildings. The brief time we spend with wildlife in the parks is beneficial to us as a bridge to break the pressure and tension of everyday life. Birds and squirrels should not be considered aggressive and dangerous. They are a part of our NYC environment. The only species that hunts, tortures and kills for fun are humans. Feeding a squirrel or giving seed to a hungry bird is an action that is done by people who are displaying the ideal traits of humanity within our society. I understand completely that there is a rat problem in NYC, not just in the parks. This has been the case for centuries in all major urban cities, nationally and internationally. Banning the feeding of Park wildlife will not stop the rats. The rats will still be there. For the NYC Parks to reduce the rat population, they have to remove restaurants, snack bars and on-site commercial vendors who supply the park visitors with the food that ends up improperly discarded garbage eaten by the rats. It is totally unfair to scapegoat the people who feed the wildlife, thus turning them into “public enemies” (within the parks). There is a DOUBLE STANDARD HERE when you excuse the restaurants and food vendors and penalize the people who visit the park to find solace and peace in feeding a bird or squirrel. This proposed rule is unfair, oppressive and does not make NYC and/or the parks look good. Furthermore, this ban wants to force the squirrels to behave like they are living in the wild, which they are not! They are living in urban parks which are artificial environments to start with. Large numbers of tourists and locals alike are part of the squirrels’ everyday experience and have been for many years. In some small parks, like Madison Square Park, the squirrels are literally on view any time they come down from their tree -No escape from view and/or human interaction. In fact, tourists return purposely year after year to engage with our NYC park squirrels. Are you going to ticket and/or arrest them too? While cities are also home to other animals, Etienne Benson, assistant professor in Penn’s Department of History and Sociology of Science, believes that the “intentional introduction of squirrels to America’s green spaces was essential to maintaining people’s health and sanity." As published in “Journal of American History," squirrels were brought to parks to alter people’s conceptions of nature and community. Squirrels play a key role, mainly due to human’s ability to connect more easily with mammals. He notes that squirrels’ readiness to trust humans and their ability to flourish in the heart of the city seem to make them living proof of the rewards of extending charity and community beyond the bounds of humanity

Barbara Hohenberg Tue, 02/26/19 - 13:43 Folks who feed birds or squirrels in NYC parks are generally aware of not giving bread, which is bad for them. Folks who feed animals in NYC parks generally only bring an amount (of nuts and seeds) that will be consumed immediately, and not become waste (i.e. will not attract rats). Folks who eat in parks should empty their trash in the designated bins. Folks who are hired to empty trash bins should do it in a timely manner. An overflowing trash bin attracts rodents, not seniors or children feeding birds seeds, or nuts to squirrels. Some common sense is needed in this discussion. Let us hope that the rules will come down on the side of common sense!

Kerri Kovac Tue, 02/26/19 - 14:03 I am in opposition to this rule because no exception was mentioned for bird feeders. Please allow bird feeders to remain in place. The turnover at these feeders is high and I doubt that there is anything left behind for rats. Bird feeders bring smiles to the faces of people watching birds eating the healthy food that is placed inside of the feeders. A public education campaign against other forms of harmful wildlife feeding would be a better course of action.

Kristy Trzaska Tue, 02/26/19 - 14:47 I strongly oppose the adoption of this rule. I am a birder who wants to be able to share this hobby with my 22 month old son once he is old enough to do so and I cannot think of a better way to get him interested than to visit the bird feeders in parks where he can see a lot of bird action at once so he will not get bored. Bird feeders in city parks are usually heavily and frequently visited by birds which substantially reduces the risk of attracting rats or spreading disease since food is rarely left behind. The amount of food given to city birds is a drop in the bucket compared to the amount of garbage left behind by park goers.

Jeana Fucello Tue, 02/26/19 - 17:39 I'm in favor of these proposed rules. Aside from the reasons listed, the continued feeding of wildlife is harmful in a number of ways, including making the animals believe it is a natural, consistent food source. I think it is also important to note that many people are not savvy to what foods these animals naturally eat and this could prevent them from ingesting harmful foods. Overall I believe that people can and should enjoy the presence of these animals at a respectful distance.

Jeffrey Kolodzinski Tue, 02/26/19 - 21:39 I fully support this policy. Keep the “wild” in wildlife.

Chelsea Lawrence Tue, 02/26/19 - 22:11 I support this rule

Jared Johnson Tue, 02/26/19 - 23:02 I strongly appose these new proposed rules. Back when I started birding, I wasn't sure how I felt about feeding. After spending a large amount of time in the park, I have come to the conclusion that Central Park has developed a unique eco system between humans and animals. Birds have already become dependent on humans through crumbs, dropped food, trash, etc. and I believe that banning feeding would be a mistake. The people who feed the birds typically will know what is right to feed them. The people who I have met who partake in feeding have always been passionate and caring about these animals. I have had a great amount of joy through interacting with these animals and I never felt that I was harming them in any way. If they were being harmed, I would not do so. A side note on the concern of animals becoming aggressive through feeding: I've never heard of a case that involved a Tufted Titmouse, Downy Woodpecker, Cardinal or any bird that has taken seeds from my hand becoming aggressive and injuring someone. If you're going to ban feeding a form of wildlife, I suggest you leave the birds out of it and go after the squirrels.

Muen Chen Tue, 02/26/19 - 23:27 I oppose the adoption of rules proposed under "Prohibition on Feeding Wildlife in Parks". Problems with the proposal: ---> The proposal says nothing about existing bird feeders in NYC public parks, such as the bird feeder in Central Park, and the bird feeder in Prospect Park. Those bird feeders attract wild birds like finches, cardinals, blue jays, woodpeckers and are a delight to any park visitor who want closely observe the workings of wild life. ---> There is also a not insignificant number of birders who bring material (like plain dry-roasted seeds) that are appropriate for bird consumption to feed wild birds as they visit NYC public parks. They don't throw away bird feed around randomly, because why would they waste material that they just carefully selected for their avian neighbors? They also don't need a big bag of feed to attract birds, since even just a little is sufficient - like 20 dry roasted sunflower seeds is enough to attract a couple of chickadees. They also don't feed birds with processed carbohydrates such as bread, because they know those material are bad for birds' health. ---> Most studies conducted on this subject show bird feeding in general tend to have a small net positive impact on the small subset of wild birds that utilize human feeding. Link to one of the studies: Link to an article from ---> Alternatives: ---> If you want to reduce rodent population, ban littering; don't ban bird-feeding. --> If you want to keep NYC pubic parks clean, ban littering; don't ban bird-feeding. --> If you want to help wild birds, ban feeding birds with processed carbohydrates and/or ban feeding water fowls; don't ban bird-feeding. --> If you really want to help wild birds, do something about window collision that causes death to hundreds of thousands of wild birds during migration; don't ban bird-feeding. --> If you REALLY REALLY want to help wild birds, bring back their habitat, especially those that are important to critical species; don't ban bird-feeding.

Margaret Duffy Wed, 02/27/19 - 0:02 1. I hope this will not create a ban on already established bird feeding stations. 2. I also have concerns that this will be unenforceable, like the ban on smoking or on riding bikes on foot paths. Police and rangers cannot be everywhere.

Candice Whitaker Wed, 02/27/19 - 1:53 It is stunning that NYC Parks is even considering this cruel and feckless proposal. It needs to be vehemently opposed on every level. To begin with, the proposal is inhumane -- towards animals and people. It seeks to criminalize a behavior that in a sane world is considered altruistic and compassionate. It particularly targets the elderly, the disabled and children; those who most frequently feed wildlife and represent the most vulnerable and defenseless in our culture. It condemns to a cruel death of starvation, many animals dependent upon human support, especially during winter. These include but are not limited to, abandoned domestic ducks, sensitive bird species, some migratory birds and even some young birds not yet capable of flight. (The latter especially true when landscapes are altered or developed.) Last summer for example, 8 of 9 goslings starved to death at the Central Park Reservoir after the birds "natural food sources" (grass and plants) had been completely chopped down along the surrounding rocks. One cannot demand that wildlife live "on natural food sources" when those resources have been destroyed or eliminated. Such is tantamount to animal cruelty. Reality is that NYC parks are not a natural, "wild" environment and it's animals are not the feral animals of Montana or Yellowstone. On the contrary, having been born or hatched in city parks, most urban animals are well acclimated to humans and some are even semi-tame. One cannot expect the same behavior from them as the wild bears or wolves of Wyoming -- nor would we want or tolerate such in a city park. Sadly, much wildlife has disappeared from city parks over the past decade. Swans no longer grace the lakes of Central Park, resident Canada goose populations have been decimated in city parks and last year, the raccoon population in Central Park was severely decimated. Many people also report seeing fewer squirrels than what was normal only a couple of years ago. The fact is, animals across the globe are under pressures from habitat loss and destruction, as well as c!image change, illegal poaching and over-hunting. We are currently in the midst of the "Sixth Great Mass Extinction. " Please don't add to these tragedies by criminalizing altruistic behavior meant to try and save disappearing species in our parks.

Melanie Testa Wed, 02/27/19 - 5:47 The birds need us, they need to pass through the area, birding is a pass time and hobby for New Yorkers and outdoor space to do it is essential. Regulate litter. Educate the public about what rats and vermin like and how to avoid attracting them. Ban feeding birds carbohydrates like bread. Don’t ban bird feeders.

Richard Aracil Wed, 02/27/19 - 7:00 I support the proposed rule change. Feeding wildlife promotes unnatural behaviors, unhealthy diets, dependency on humans, vermin problems, aggressive interactions and issues with animals becoming a nuisance.

Rachel B Wed, 02/27/19 - 11:19 I oppose this proposed rule. Due to the character limit in the comment box, I have attached my opposition statement to explain my position.

Sarah Katz Wed, 02/27/19 - 14:22 I STRONGLY OPPOSE this proposed ban on feeding the wildlife in NYC Parks. This rule would stop people from engaging in an experience that is educational and serves to enhance their lives. I have observed from daily visits to Madison Square Park that people who are feeding the wildlife are very much aware of the proper foods to feed them. It is an arrogant supposition for those who support this ban to claim that wildlife feeders are not savvy enough to know what the squirrels and/or birds need to eat. Just because people feed the wildlife does not mean they are ignorant. Part of caring about the wildlife is investing in learning about their nutritional needs. I have observed wildlife feeders kindly explaining to other park visitors what things are good and what things are harmful to feed the wildlife. Most people who love the wildlife are interested and happy to acquire this knowledge. While there are a very small amount of people who may throw bread to the wildlife, they are not the rule, but rather the exception when it comes to the wildlife feeders. I do not approve of throwing out bread and foodstuffs of this nature to the wildlife because that is no better than those who leave their unfinished sandwiches on park benches when they don’t feel like walking over to the trash bin. The difference is this: I have witnessed those who had initially came in with bread to feed wildlife actually stop feeding the bread and subsequently bring in the more appropriate nutritional nuts and seed, once they found out the bread was harmful. On the other hand, those who leave their unfinished lunches and garbage are usually not open to changing. Their selfish behavior is not for the good of anything or anyone except themselves. They simply find it too inconvenient to walk to a trash can. They complain about rats but dump their garbage on the ground. Instead of issuing summons to wildlife feeders for giving birds/squirrels seeds and/or nuts that are quickly consumed, why isn’t the garbage situation being addressed? It is painful to hear the parks department attempt to misguide the public into thinking that wildlife feeding keeps the wildlife from foraging for the food they need, especially when there is nothing to forage. I am well familiar with the trees in Madison Square Park and all but one, perhaps two bear acorns in the fall, and certainly not enough for the park’s squirrels. The parks describe the squirrels as “aggressive” when a more realistic description would be “friendly.” Aggressive has a much more negative connotation and keeps the public fearful. Control through fear has always been a popular strategy throughout history and banning the feeding of wildlife this way is despicable and irresponsible. Why would the parks want to advocate for a hostile environment instead of one that creates a respectful and humane environment? PLEASE DO NOT ADOPT THIS AMENDED RULE BANNING THE FEEDING OF NYC PARKS WILDLIFE.

Mary Flaherty Wed, 02/27/19 - 14:59 I am against this rule. From my experience, the people who feed the squirrels and birds do so responsibly. Without the help of empathetic New Yorkers, the animals would really suffer during the winter, particularly when there is a lot of snow and ice. I think a more sophisticated, nuanced approach should be sought to deal with rats.

Scott Sobel Wed, 02/27/19 - 16:41 I think that any rule adopted that addresses feeding of wildlife absolutely must address the fact that there are existing feeding stations in the parks that may continue to be maintained. Birds have lost tremendous amounts of their natural habitat and cannot maintain a healthy population without our help as they migrate through our area. I believe that if wildlife is given healthy food at known feeding stations, this is not an issue at all. I also think that many people derive joy in their lives from the act of communing with and sometimes feeding wildlife. If they are providing healthy food for the wildlife in our region, I think that is probably a good thing. Again, humans have already had an enormous impact on wildlife and habitat, and the east cost megalopolis is certainly no exception. Anything we can do to help wildlife be healthy and survive is a good thing and should not be curtailed. At most, perhaps the city should consider signage in popular park locations about what constitutes healthy food for the wildlife and explicitly explains why bread is very bad, especially for birds. Please do not implement any rule that restricts the existing feeding stations in the parks and please consider how little habitat animals and birds have in which to practice the wild feeding behavior you would like to encourage. Until they have sufficient habitat, restricting access to food will only send wildlife populations into a rapid decline. Thank you for your time.

Elaine Kubiak Wed, 02/27/19 - 19:11 I vehemently oppose this rule and will boycott all park restaurants if it is put into effect. I will also investigate exactly where the money from these proposed fines goes. I doubt it will go to the park as this whole thing is a scam excuse for the city to reduce funds to the parks. My complete statement is included as a separate file to be sure you don't have trouble reading it.

Elaine Kubiak Wed, 02/27/19 - 20:52 I vehemently oppose this rule and will boycott all park restaurants if it is put into effect. I will also investigate exactly where the money from these proposed fines goes. I doubt it will go to the park as this whole thing is a scam excuse for the city to reduce funds to the parks. I will also include my statement as a separate file to be sure you don't have trouble reading it.

JASON TRACHTENBURG Wed, 02/27/19 - 21:44 I strongly oppose this proposal. I support the feeding of NYC wildlife. I suggest an information campaign be presented to inform citizens of the best methods and types of food to be given to specific wildlife. We have a limited amount of wildlife in this city, and they have small resources of food, and it's our responsibility to care for these animals. Piña Wed, 02/27/19 - 22:16 I strongly oppose this proposal. As it is now, nyc wildlife has very few if any resources for food. There are no bird baths or fountains where the animals can get fresh water. This would create healthy animals. Feeding birds in our psrks is a peaceful activity for both humans and the animals. Tourist come from all over the world to enjoy watching and taking pictures of people interacting with the wildlife. If you are concerned about rats, maybe you should get better cleaning staff. Also how sad is it that rats are only celebrated when they are eating pizza or doing some other idiotic human behavior. Rats are incredibly intelligent and sentient beings too. Can we just have more compassion for the animals instead of targeting them with harsh laws that will make their lives more difficult than they already have.

gloria marsh Thu, 02/28/19 - 3:05 I STRONGLY OPPOSE this proposed ban on feeding wildlife in NYC parks. It is Inhumane. The level of ignorance in the NYC Park's Dept. proposed ban is unbelievable. There is not much for wildlife to forage from nature in a" Concrete Jungle" like NYC. especially in winter. The Parks Dept. is trying to control the rat population by starving wildlife?? Seriously ? They should start by emptying the overflowing garbage cans in the parks. They should be fining people who are leaving their trash all over. If they want to make the parks safer they should start by addressing Dogs running OFF leash and bike riding on walking paths. They shouldn't be instilling fear in the public by giving false and incorrect information . SHAME ON YOU ! I think educating the public about what and how much to feed and about the wildlife is a good thing. This ban is Ignorant and lazy. It's despicable.

Cathy Weiner Thu, 02/28/19 - 8:58 Unfortunately, many city dwellers have no interaction with nature and do not visit their parks enough to understand they are habitats for wildlife and treat them with disregard. Those that do visit, find the experience intimately rewarding and a reminder that there is life outside of our scope of home to work and back. Parks are vital for its visitors and importantly the wildlife that visit and live in these habitats. Vermin such as rats, cats, raccoons that bring disease are a problem that need to be addressed. The need for properly built and maintained garbage receptacles and education in throwing garbage into them is a priority in addressing rats. As a birder, I do not believe that educated park visitors who bring handfuls of seeds to feed birds in the winter contribute to this problem and have not seen vermin at the bird feeders in Central Park which are properly maintained. I have witnessed people throwing loaves of bread in both the Central Park and Prospect Park Lakes as well as those that throw their leftover snacks, pretzels, etc. which is clearly harmful to the wellbeing of the wildlife and its habitat. Do Not Feed The Wildlife signs should be updated to include information helpful in educating the public. Signs might be an eyesore to some but if it helps stop the accumulation of garbage outside of its proper receptacle than it is a small price to pay. Other educational outreach programs should be implemented regarding garbage disposal which is much more of an issue with vermin. If you do not aggressively maintain the cleanup of garbage you encourage the rat populations to continue.

Teresa Vuoso Thu, 02/28/19 - 12:05 In the Concrete Jungle, the Park is where we all get to interact with the GORGEOUS birds, ducks, and beautiful squirrels when we feed them what they need. It is the JOY of my life feeding them by hand, holding them, and receiving their LOVE and giving them LOVE each day. They live in the park, people, visitors do not. We need to respect them, care for them, and FEED them. There is nothing available for their daily requirements and we all see the Parks Dept. does not even provide a Clean Water Source for any wildlife anywhere. Squirrels need nut bearing trees they are native to, such as , hazelnuts, walnuts, and seeds, sunflowers, berries.. NOTHING is there. Acorns are Toxic to squirrels. The birds needs a list long of daily requirements of Nutrition not found in a park or the city of NY. We have been feeding the birds because we love them. We are Blessed by God to have these Beauties that bring such JOY to us. Children come daily to see them and hold them, love them, and feed them black oil sunflower seeds, and bird seeds. They are so excited to hold the birds in hand and feed them. Birds are clean, not dicease carriers, get educated. People carry diseases. If not fed well, they will suffer from malnutrition. I have been educating the chilkdren and adults daily for over five years now in Riverside park. NO BREAD, NO RICE, NO MUFFINS, CEREAL, Nothing with flour. It is deadly, I know, I am a rescuer and I bring countless birds and gulls, geese, ducks to the hospital weekly. They all need clean water, they should not be given bread. People are hurting them and piercing them, chasing them with dogs ogg lease. Education comes from the FEEDING WITH LOVE EXPERIENCE I share with thousands of people daily for years. They now run to Riverside Park to feed the nuts and seeds to these PRECIOUS New Yorkers filled with beauty , love, and joy. They give us JOY and we should see to it they experience the same. STARVATION now proposed! SHAME on you to even think of this. Rats have been disturbed by construction to their hones in the park. They eat the food PEOPLE leave behind, trash never thrown in trash cans. Rats have no interest in bird food, duck food, or squirrels food. .

ROBERTA SHIELDS Thu, 02/28/19 - 12:57 I strongly support the proposal to ban wildlife feeding in NYC Parks. Feeding is well intentioned but not good for wildlife for all the reasons stated in the proposal.Children can be taught to value and respect wildlife in many ways. Feeding wildlife makes people feel good, it does not help, and can even harm the wildlife we so cherish. Let's not continue to put our own pleasure above what is best for the animals we wish to protect. Teach your kids about wildlife, have the kids photo wildlife, write poems about wildlife and appreciate web cams. Feeding wildlife ultimately just gets wildlife into trouble and when that happens, wildlife always loses...for what? to provide us humans with a fleeting "feel good moment"?....let's be better than that and do what is best for wildlife which ultimately is best for us all.

Christine Ramos Thu, 02/28/19 - 13:26 I oppose this rule. I live in Inwood and visit Inwood Park everyday. We have a large Hispanic community here who love to visit the park with their families, grandparents and children and feed the birds and squirrels. It is part of daily life here. Children learn about wildlife by feeding the birds and squirrels. It's one of the greatest experiences living in New York City. I have many elderly friends and neighbors who visit the park everyday just to feed the birds. It is the one thing that they look forward to and gets them out of the their apartments. It is wrong to lecture and scold and go so far as to fine and treat these people like criminals. This is discrimination! In the winter time the birds and other wildlife are starving. Once they are fed, within seconds all the food is eaten up and gone. No feed remains.The same for the squirrels. There are no obese birds or squirrels, they are starving in the winter. The problem with Rats is 100% caused by people and lack of staff in the park. In Inwood Park there is a massive amount of food and trash left all over the park by people. I see no staff, rangers who say anything to them at all. The food and trash is left there for days. It is a common complaint amung residents here and has been reported in the media. The rats come out to eat it which is right by residential buildings. The Parks need to educate people on throwing food and trash on the grass. There needs to be more park workers who pick up the trash. Even the trash bins in the park are overflowed with garbage and food falling out into the street. The trash bins are filled to the top so people throw trash on the floor. Nobody picks up the garbage and it just lays around. Also there is a lack of police in the park. Many people stay in the park once it closes, blasting music through the night. Nothing is done about it. This affects the health and quality of life for many residents.

Edward Butler Thu, 02/28/19 - 14:39 I oppose the proposed rule. This rule is merely an attempt to collect fines from people engaged in a harmless activity, frequently seniors on a fixed income, and to separate humans from the animals in their environment in order to make it easier for authorities to "manage" wildlife as they see fit without resistance from humans who have bonded with them.

John Waite Thu, 02/28/19 - 14:59 I strongly OPPOSE this regulation as both cruel and misguided. It is cruel to criminalize what is, in fact, an act of kindness. It is cruel to the families, the old, and the lonely who find solace and enjoyment in feeding our birds and squirrels. If rats are a problem, then deal with littering and deal with garbage collection. If there is a problem with what people feed the birds and animals, then instruct them. How can we teach our children to love and respect nature if we tell them it is somehow wrong to feed the hungry. Every day I see the light in children's eyes when they watch a tiny bird land on my outstretched hand and realize that the creatures that inhabit our parks are little beings and not just something to chase and throw a stick at. If you don't interact with nature you can't come to love it. And our parks will beome just another place to walk through while checking the Twitter feed on your iPhone.

Allie Taylor Thu, 02/28/19 - 15:03 Voters For Animal Rights believes that the rule is overly punitive and overly broad. It punishes those who care deeply about animals and are feeding them out of kindness, not malice. Exceptions for wildlife rescuers and rehabilitators are vital in order to ensure the survival and protection of vulnerable animals. Our recommendations: • Modify “animals” to “wildlife,” and define wildlife as not including abandoned domestic and exotic pets, and other domestic animals, including farm animals. • Provide an exception for qualified individuals, including professional or licensed rescuers and rehabilitators, to feed wildlife for the purpose of aiding or capturing injured wildlife or abandoned domestic and exotic pets, and other domestic animals, including farmed animals. • Offer violators the option to attend an information session about New York City wildlife (online or in-person) which would address the specific harms caused by feeding wildlife as an alternative option to paying a fine. Please see attachment for full commentary.

Stuart Eaton Thu, 02/28/19 - 16:43 I am in strong opposition to this proposed ban on feeding the wildlife in NYC Parks. It should not be approved. It is a dismal indictment on the state of humanity when the suggested methods for children to appreciate the wildlife in our city are for them to watch squirrels and birds on video screens, webcams or other technology, limiting them to “auto tune” experiences. To say that those who feed the animals do so because it makes them feel good demeans the compassionate caring people who actually help the wildlife. Most people who sincerely help a person or animal do not do it because it makes them feel good. They do it because it is the right thing to do! It is amazing to me how supporters of this ban can make broad sweeping accusatory statements when they write that feeding the animals does not help them. If squirrels in some NYC Parks cannot possibly forage for the proper foods because the trees and shrubs needed for their sustenance have been landscaped out of the parks, then feeding them the proper food DOES help them. Many city parks do not supply an adequate natural food source for them. Effective Educational programs should have been the first course of action and as such a city-wide Wildlife Educational Initiative with pamphlets, seminars, events, etc. should have been proposed or simply implemented. Instead, NYC Parks made the proposal to criminalize the kind hearted people who feed the wildlife. Many of these people are seniors who would be put at a hardship, if fined. This is extremely unfair and discriminatory. This proposed new rule would benefit neither the people nor the squirrels or birds of the parks.

Margaret Lee Thu, 02/28/19 - 16:47 As a wildlife-loving resident of downtown Manhattan I strongly oppose the Parks Dept proposed ban on feeding wildlife in city parks. My objection comes from many years of close observation of and interaction with wildlife in parks and throughout the city. While many people walk by our wildlife with scant regard, I have been closely involved with their lives, noticing the many ways in which they suffer through a combination of neglect, lack of knowledge, and outright cruelty. The suffering of NYC wildlife has been especially evident to me in the two parks I know best: Washington Square Park and Union Square Park. Both parks exemplify the ways in which wildlife are subject to human insensitivity, which over the years has deprived them of the fundamental resources they need to survive. During the massive renovation of Washington Square Park, for example, their needs were sadly ignored by the Park as many animal lovers came forward with suggestions on how to improve their lives. The compassionate ideas, such as accessible water fountains and food-bearing trees and plants, fell on deaf ears. Consequently the wildlife continue to lack the food and fresh water necessary to sustain their lives, being very much dependent upon the haphazard handouts from visitors, and the committed care of those who look after their daily welfare. Most people walking through this and other city parks give no thought to the fact that, while they are enjoying a respite in their day, they are actually visiting their neighbors’ home - the wildlife who live in the parks, struggling in an anti-nature and deeply deprived habitat. These are sentient creatures with families and feelings, living beings who hunger and thirst, who feel pain, and who also bring great joy to the visitors who care enough to observe their individual personalities. Casual visitors are unlikely to know the sad reality that NYC wildlife are in a minute-to-minute struggle for survival, living with a shortage of food and water, while being constantly subject to the behavior and intent of human visitors - dog-walkers, ball players, cyclists, stakeboarders, gardeners, maintenance workers, netters, tree pruners, traps, and all manner of efforts to eradicate them. In a world where compassion is in short supply, NYC needs to seek ways to improve the lives of our animal neighbors, not devise more ways to cause harm and further reduce the quality of their lives. It is one thing for the Parks Department to lack mercy, it is quite another for it to demand complicity from kindhearted members of the public who, when they see a creature in need, answer their innate obligation to do everything within their means and ability to help. It is my fervent hope that NYC would widen its circle of compassion for our wildlife and thereby be a great example to our many visitors from around the world.

D Flaherty Thu, 02/28/19 - 16:52 I STRONGLY OPPOSE the proposed ban on feeding birds and squirrels in NYC Parks. The proposal’s stated list of reasons for the rule is disingenuous at best. The proposal states that rats are “attracted to all types of food in properties maintained by NYC Parks” but does not propose banning people from eating in parks, or banning farmer’s markets, or increasing enforcement of littering – all which would have a greater impact on reducing food in the parks that might attract rats then banning birdseed. Putting out wild birdseed for the sparrows or peanuts for the squirrels certainly did not cause the distemper outbreak in raccoons. It is my experience that the people who feed birds and squirrels are very aware of the proper food to feed them, and anyone who is unaware could be educated by placing information signs. This proposed ban is mean-spirited and would negatively impact the thousands of people who delight in feeding the birds and squirrels in the park. It would also negatively impact the animals who benefit from receiving seeds and nuts, especially in the snowy winter months when other food sources are less available.

Edward Gaillard Thu, 02/28/19 - 16:54 I understand the problems the proposed rules are intended to address, but I oppose them as currently drafted. The current draft doesn't not include authorization for existing bird feeders, nor does it say how the Commissioner's authorization for feeding areas can be obtained. Allowing feeding of "personal pets" is a loophole that will be used by people feeding feral cats on park land, which is destructive to all wildlife in the parks, and illegal under current rules. Let us not make the illegality of feeding feral cats ambiguous! Additionally, promulgating new rules without any plan for enforcement is futile. For example the feeding of raccoons is already prohibited, but this is never enforced. Finally, if you do have a plan for enforcement, than you must answer why these rules should take precedence over existing rules which are never enforced, such as the dog leash rules. The department should draft rules more narrowly tailored to the specific behaviors that need to be reduced, principally the dumping of large quantities of bread around ponds. I also urge the department to step up enforcement against feeding raccoons and feral cats, and against allowing dogs off leash in protected areas such as the Ramble in Central Park.

John Di Leonardo Thu, 02/28/19 - 19:25 While Long Island Orchestrating for Nature (LION) agrees with the spirit of the proposed rule to prohibit citizens from feeding wildlife, the proposed rule is overly broad and needlessly impedes reputable rescuers and rehabilitators from aiding domestic and exotic pets and farmed animals who are often abandoned in New York City parks. Fowl, and other animals, feel pain and fear and abandoning a domestic bird is the same as abandoning a dog or a cat. Such birds can’t make it on their own. When they’re abandoned to fend for themselves, they often starve or freeze to death, because most can’t fly or migrate. Though animal abandonment is a crime in New York, fowl abandonment is common in New York City and if rescuers and reputable organizations like LION—who volunteer their services to better New York City—are prohibited from helping them, which often includes baiting them or sustaining them with feed until they are able to be rescued, these animals languish and die. LION agrees: wildlife should stay wild. But abandoned pets and farmed animals are not wild, and they cannot become it. Long Island Orchestrating for Nature agrees with the following suggested amendments to this proposed rule and urges the New York City Parks & Recreation Department to only pass it with the following revisions: • Modify “animals” to “wildlife,” and define wildlife as not including abandoned domestic and exotic pets, and other domestic animals, including farmed animals. • Provide an exception for qualified individuals, including professional or licensed rescuers and rehabilitators, to feed wildlife for the purpose of aiding or capturing injured wildlife or abandoned domestic and exotic pets, and other domestic animals, including farmed animals. • Offer violators the option to attend an information session about New York City wildlife (online or in-person) which would address the specific harms caused by feeding wildlife as an alternative option to paying a fine. Sincerely, John Di Leonardo Executive Director, Long Island Orchestrating for Nature (LION) MS, Anthrozoology

JoLinda Ruth Cogen Thu, 02/28/19 - 19:49 I live across the street from Dorrance Brooks Square and Chair of the Parks Committee for the Dorrance Brooks Property Owners and Residents Association, Inc. in Harlem it’s located across from St. Nicholas Park and a subway station is in the square as well as across the street at St. Nichola Park. My neighbors and I help maintain the Square. People “travel” from far away dropping “cooked peas and rice” pizza, “uncooked rice” bread, bags of chips, popcorn whatever to feed the birds – everyday. That has caused “herds of rats” who are no longer afraid of people! These rats then begin to feed in the garbage cans and run in and out of the subway stations feeding more in broad daylight. Thus, the purpose of the park to sit, rest, read and have quiet conversation is defeated for we all run from the rats! There was a sign once from parks “if you feed the birds you feed the rats.” Those should be posted again, we have made our own and are “policing” ourselves. Bird feeders are belligerent with us and we tell them you can feed the birds “in front of your house do not make a pilgrimage in front of ours.” We clean the debris up that the birds do not eat. Designated areas like a bird sanctuary is fine where folks can feed the birds - that is an exception. But across the street from our houses is not tolerable. The rats run from the park to our homes, our cars, to the garbage cans, through the sewers and the subway stations. We have witnessed the rats chasing the squirrels and “eating the fattened sparrows.” This is UNACCEPTABLE! No feeding the birds in parks. A few ticket blitzes and folks get the message._

andrew garn Thu, 02/28/19 - 20:11 I strongly oppose this senseless ban. The NYC Department of Parks can barely enforce laws (littering, smoking, skateboarding, bike riding, dogs off leash etc) that are far more injurious to the public then feeding wildlife. Why deprive citizens of the pleasure of interacting with what little nature we have in the city? Instead of handing out fines, I would suggest that the NYC Dept. of Parks would direct their energies to educating people to what type of foods would really help animals (seeds, nuts, berries, etc) and to not feed wild animals poor quality human food (bread, rice, popcorn, etc). The proposed law is basically unenforceable because so many people feed animals and will continue to do so. It is normal that many people want to help the animals that live so close in proximity to us. This compassion is deeply ingrained in humanity. This would not stop because of a new city law. Many animals, including pigeons and squirrels live tough lives, shortened by the harshness of city life and many people who have limited access to nature want to help them. In my observations of pigeon feeding in local parks, I notice that birds (pigeons, sparrows, morning doves and starlings) will eat all of the seed left for them- leaving nothing for rats. It is food garbage carelessly left behind and overflowing in garbage cans that lures rats. If there are overpopulations of animals including raccoons and deer, work on solutions that control reproduction humanely, don’t take away the simple pleasure of feeding birds and squirrels from people craving nature. Andrew Garn

Allison Thaler Thu, 02/28/19 - 21:02 I am a NYC resident and I am absolutely against the proposed rule of prohibiting feeding of animals in the park. This rule change would doom ducks that have been dumped in the lake to death by starvation. I'm sure this is not anybody's goal, but that will 100% be the result. People dump their ducks in the lake bc they don't want them and possibly think this is a good place to bring them. But these ducks are not wild, the are domesticated and absolutely cannot fend for themselves. It is against the rules of course to dump wildlife but it happens anyway. There are wildlife rescuers that are willing to rescue the ducks from the lake and bring them to sanctuaries. They allow this, but won't let them during winter. So these rescuers donate their time and feed the ducks so they will survive, period. This feeding is life and death for these ducks, who have ended up there through people breaking the rules of the park. Certainly not their fault. I propose a solution that will immediately stop the feeding of the ducks and at the same time, let them survive. This would be to allow these rescuers to remove the ducks during the winter. I gather the reason is bc the park is concerned that there may be ice on the lake. But ice knows no season, it only knows temperature. So if it is 40 in December or 70 in May, it is the ice. The would be a humane, common sense solution to the issue. I propose that the rule include a method for the rescuers to save these ducks during the winter if there is no ice on the pond or the temperature is above let's say 40 or even 45 to be sure. This happens countless times all winter long. This would save lives of animals, be humane, and stop the feeding of the ducks. Thank you.

Mayra Bermeo Thu, 02/28/19 - 21:08 I partially support the proposed rules by the Parks Department. But other factors have contributed to the current issue. The proposal punishes those, particularly the elderly and children, who care for the local wildlife. Instead, there's a real opportunity to inform the public about how we can best share the environment with wildlife. Some forms of feeding are dangerous to wildlife. Bread offers no nutrition value to waterfowl. In severe cases, waterfowl develop angel wing, permanent wing deformity. Animals can become habituated to the constant feedings, lose the fear of people and lead to nuisance/ aggressive behaviors. These consequences have detrimental effects on wildlife welfare and quality of life. But also create public resentment towards wildlife. And we start to consider severe measures like culling or relocation. It’s inhumane and an “easy fix” but it also doesn’t work. Research shows that the culling of cats, birds and other species is ineffective. Other issues have escalated environmental pollution and human-wildlife conflict. It’s irresponsible human behavior and action. Officials need to enforce the illegal dumping of pets and domestic animals better. It includes cats, rabbits, turtles, and ducks. These animals aren’t equipped to survive outside a controlled environment. During the winter, the grounds freeze and that limits the distribution of natural food sources. Both the public and officials have been irresponsible in the proper disposal of garbage. Garbage attracts rats. Rats are a problem because officials will start to consider the use of rodenticide, which harms raptors. These majestic creatures are flourishing here in NYC and are a part of the wildlife environment. People also dump bread or junk food into our ponds and parks. When our actions are irresponsible, we harm wildlife, and we pollute our environment. These bans are unrealistic and will lack consistency. There’s much work to do before we can even consider the measures proposed by the Parks Department. We need to change public perception about wildlife and wildlife feeding. We need public education and regular enforcement. We need to incorporate animal welfare to check what feeding activities are acceptable and helpful toward conservation. With this in mind, we should introduce exceptions. We should consider allowing adequate winter supplemental feeding. Professional rescuers and rehabbers should be able to use food to capture and lure injured or sick wildlife. Fines especially hefty fines also aren’t the answer. It will impact the vulnerable or marginalized individuals who care for wildlife. We need to enact education programs to prevent human-wildlife conflict. But we also need to learn how we can co-exist with wildlife in a manner that’s healthy and responsible.

Ruth McDade Thu, 02/28/19 - 21:13 I oppose this rule. When there are injured and/or abandoned domestic and area wildlife, exotic pets, and farmed animals in NYC, professional or licensed rescuers and rehabilitators often feed the animals in an effort save them. Restricting their ability to feed these animals would impede their work, it is also inhumane. I recommend focusing efforts on more diligent trash collection.

Janice L Blake Thu, 02/28/19 - 21:44 -Modify “animals” to “wildlife,” and define wildlife as not including abandoned domestic and exotic pets, and other domestic animals, including farmed animals. -Provide an exception for qualified individuals, including professional or licensed rescuers and rehabilitators, to feed wildlife for the purpose of aiding or capturing injured wildlife or abandoned domestic and exotic pets, and other domestic animals, including farmed animals. -Offer violators the option to attend an information session about New York City wildlife (online or in-person) which would address the specific harms caused by feeding wildlife as an alternative option to paying a fine.

John Dugan Thu, 02/28/19 - 22:17 I support the proposed rule change. The proposed change is a common sense approach to closing a loophole in the existing rule. Feeding wildlife is detrimental to their health and the health of the ecosystem. Wild animals do not need to be fed. They can find their own nutritious food. People frequently feed birds and squirrels an improper diet, and the rule change will help prevent that from happening. In addition, birds and squirrels can get extremely aggressive when routinely fed. It is no longer enjoyable for me to walk around Willowbrook Park in SI because of the overly aggressive geese that are being fed there. The waterfowl are always approaching people, and even running after them. I have witnessed the ducks and geese chasing children on numerous occasions because they expect a handout of food from people. My park visits would be more enjoyable if I didn't have to worry about being approached by aggressive waterfowl. I applaud your efforts to make the parks a safer, cleaner, more enjoyable space for both people and wildlife.

Lars Engstrom Thu, 02/28/19 - 22:43 Though I understand the public heath concerns of pest, feeding the wildlife of waterfowl and squirrels has been a New York tradition for generations (including in my own family). I find it disingenuous of the city to pretend that the only food waste that is generated is by the feeding of these animals. I live a block away from Prospect Park and it is clearly not a priority of the Parks Department to curtail the massive amount of trash, litter, food and human waste that is generated in the Park which has nothing to do with feeding the squirrels and the ducks. I can only guess that this policy proposal is due to an increase in vermin, and the Parks Department is unwilling to commit to public education and publicity to encourage park users to be respectful of their park, use proper trash cans, and to leave it how they found it. Also, the Parks Department fails to replace the many trees and bushes that have fallen or removed that provided natural sustenance to wild animals that both live in the park and pass through, often on migratory routes. If you are against animal dependency of handouts, manage the greenspace you have as you would any other ecosystem under the protective custody of a park. The animals aren't the problem, abusers of the park are, and it is irrational and senseless to nix a classic New York act of kindness in the name of a problem that has nothing to do with it.

Lisa Scheppke Fri, 03/1/19 - 8:08 After reading these comments, it is apparent that far more people oppose the rule than support it. Of the minority that do support it, many of those requested exceptions to the rule which means they do not want it enacted as written. Seeing some of the impassioned comments and knowing that NYC is a litigious place, it is possible that the City may be sued by animal rights activists if this ban is enacted as written. This is another reason that the proposed rule should not become a rule.

andrew garn Fri, 03/1/19 - 9:41 I strongly oppose this senseless ban. The NYC Department of Parks can barely enforce laws (littering, smoking, skateboarding, bike riding, dogs off leash etc.) that are far more injurious to the public then feeding wildlife. Why deprive citizens of the pleasure of interacting with what little nature we have in the city? Instead of handing out fines, I would suggest that the NYC Dept. of Parks would direct their energies to educating people to what type of foods would really help animals (seeds, nuts, berries, etc.) and to not feed wild animals poor quality human food (bread, rice, popcorn, etc.). The proposed law is basically unenforceable because so many people feed animals and will continue to do so. It is normal that many people want to help the animals that live so close in proximity to us. This compassion is deeply ingrained in humanity. This would not stop because of a new city law. Many animals, including pigeons and squirrels live tough lives, shortened by the harshness of city life and many people who have limited access to nature want to help them. In my observations of pigeon feeding in local parks, I notice that birds (pigeons, sparrows, morning doves and starlings) will eat all of the seed left for them- leaving nothing for rats. It is food garbage carelessly left behind and overflowing in garbage cans that lures rats. If there are overpopulations of animals including raccoons and deer, work on solutions that control reproduction humanely, don’t take away the simple pleasure of feeding birds and squirrels from people craving nature. Andrew Garn

K Kernia Fri, 03/1/19 - 10:10 Continuing my comment about children feeding wildlife in the zoo. Living near two parks and with a subway station at the same location underneath the two parks, is a rat nightmare. We dread the summer because we cannot enjoy either park or our own blocks because of the rat explosion that wildlife feeders are contributing to, significantly. I agree that there should be clear enforcement guidelines to accompany the new regulations.

Kolbein K Waering Jr Fri, 03/1/19 - 10:37 SHAME on the New York Department of Parks & Recreation's for its proposed birds and squirrels STARVATION CAMPAIGN. Also shame on the department for giving the public SHORT SHRIFT in adequately publicizing the SINGLE 2-hour hearing anticipated for today. THIS MATTER DESERVES FURTHER public scrutiny and comment before any "final" decision is rendered, as well as the assessment of alternative better solutions to the problem of rats in the parks. For starters, those feeding bird and squirrels should be counseled to leave NO EXCESS FOOD not specifically eaten at the time they feed the animals. That remedy would go A LONG WAY toward resolving the problem altogether. Again, this matter deserves further study and more humanistic solutions and creative approaches. Thank you for considering my perspective in this IMPORTANT POLICY CHANGE, which, again, deserves much more public scrutiny and discussion before implementing any rules or regulations changes.

Ariel Cordova-Rojas Fri, 03/1/19 - 11:57 I work at a wildlife rehabilitation center. We get in over 6,000 injured patients a year. Most of the patients we get come from the public seeing an injured animal and bringing them to us. One of the ways they are able to capture the injured wildlife is by baiting them with food. Without this, it is very difficult or nearly impossible to get close enough to the animal to save their life. As well as many people who bring us injured wildlife (in particular pigeons) feed their flocks daily or on a weekly basis) so they can get close enough to notice the injuring they have and can capture them t bring them to us. I am afraid that by making it illegal to feed wildlife, there would be a lot more injured wildlife in NYC. I agree that many people improperly feed the animals un-nutritious food, as well are creating wildlife to become unafraid of humans, but that is not always the case. Furthermore, as a rehabilitator, my goal is to re-release wildlife into nature, and to attract other animals to the region so that they are not alone, we will ocassionaly put down seed. this is a very important process for reintroduction since pigeons are flock animals, and some of the birds we are re-releasing back into the parks were orphaned or have not been outside in months so need to reacclimate with the help of others.

Arie Gilbert Fri, 03/1/19 - 13:12 I am against the proposed rules to prohibit feeding wildlife in NYC parks. See attached commentary Arie Gilbert President - Queens County Bird Club Inc.

Mary Patricia Bastian Fri, 03/1/19 - 13:30 I strongly oppose this rule change, especially if it is extended, intended or otherwise, to certified wildlife rehabilitators. Responsibly feeding the birds or squirrels is often the only interaction with nature available to urban youth and elderly. This connection creates a better humanity. In addition, the natural food resources in the park is not being managed correctly, if at all. Removing seeds, acorns and nuts into landfill rather than leaving them in situ removes their food sources. As a DSNY certified master composter, I know there are many ways to manage waste and rodent control better. I agree that garbage bags full of bread is dumping and should be enforced as such. Let's work together to educate the public and defend our wildlife using snow-fencing to create barriers for protected areas for our visiting and resident waterfowl. Please be aware that we are in the middle of scientifically confirmed Sixth Extinction and New York's fauna needs all the help and protection it can get. Please don't take this pleasure away from future generations, we can manage this.

Jane Rosen Fri, 03/1/19 - 13:43 I am writing as both a mental health practionioner and an animal lover and I need to say that as both I am STRONGLY OPPOSED to the current proposed rule to criminalize the feeding of wildlife in city parks. As a mental health practioner I would like to point out that there are many empirical studies that prove spending time in natural surroundings as well as performing acts of kindess help improve such conditions as depression, anxiety as well as alleviate isolation and promote a sense of well being and self esteem. As an animal lover I am appalled that such a rule is even being considered. Most of the folks who feed in the park are the elderly, the disabled or children. Why would we consider targeting the most vulnerable in our society when it would actually not address the problem of rat overpopulation as well. Those who feed in the park know what and how much to feed the wildlife and are not responsible for contributing the the “rat buffet.” These folks are often seen teaching others how and what to properly feed the wildlife there as well. I suggest that those who have private restaurants and concessions in the park be tasked with providing some private refuse removal and perhaps park personnel should be policing and fining those who by negligence leave litter behind when eating in the park. Not onece have I ever seen anyone ticketed for such an offense when spending time in Washington Square Park, my local and oasis in this concrete jungle. We as humans have already encorached upon the natural habitat of the wildlfe in this city and those that try to survivie in the ciry parks already live in deplorable conditions. In thinking of Washington Square Park in particular, when it was redesigned a few years ago no consideration was given to providing fruit and nut bearing trees for the wildlife who are trying to live there and those who live there have become dependent on the kindness of those who try to make up for that lack of consideration. Let us not forget that animals are sentient creatures who experience pain, hunger and thirst. I would like to add that a squirrel approaching a person eating on a park bench is a relatively tame and friendly animal who might be hoping for a handout and is not “aggressive.” Squirrels do not carriy rabies either I might add and are unlikely to spread any disease. What kind of message do we wish to impart to our children and what are we teaching them about compassion and kindness by instituting such inhumane rules? How are we teaching them to be stewards of the planet which they will inherit (hopefully that is)? Again I IMPlORE you to consider a more appropriately targteted and humane resolution to the problem at hand and say that I STRONGLY OPPOSE the proposed rule.

Roxanne Delgado Fri, 03/1/19 - 18:58 First, stop permitting people to BBQ in the parks and parkways. IT brings rats and it brings too much garbage. and eliminate all the concession stands in the parks as well since they bring odor and garbage. You are literally Barking up the wrong trees. and since I mention trees, please stop removing all the trees in our parks and Turing our parks into concrete eating pavilions. What you are doing is CRUEL. there is no food source for the squirrels in the parkway. We don' t even have trees in the parkway. so the poor squirrels are eating trash on the food or from the overflown trash cans or from dunking donuts trash across the street. provide a natural habitat for our wildlife and then there would be NO need to feed them.

Roxanne Delgado Fri, 03/1/19 - 20:33 Roxanne Delgado on Behalf of Friends of Pelham Parkway Some Facts are Friends of Pelham Parkway are - We are the City Parks Foundation 2017 It’s My Parks Bronx Award Recipients - With over 500 Votes, we won the It’s My Park Photo Contest for 2018 - We won the 2019 Bronx Daffodil Award which we will received at the 2019 Daffodil Breakfast on April 23rd - We were founded in July of 2017 and the main reason was because I saw a squirrel sitting on a pile of garbage dumped on the parkway. - Since 2018, we held National Squirrel Appreciation Day on Jan 21th. In response to the purpose of the proposed rule to Food Sources available for rats: Therefore we need to stop people from eating in parks property because they are the main source of food. They litter all over the parkway with their fast food containers. In the parkway, we have people who leave all their food and trash all over the grounds and benches. Also, to eliminate food sources we need to empty out the trash cans more. Due to lack of fund for parks operations and maintenance, we have lots of overflown trash cans which results in more trash blown over unto the grounds. Please read attachment for the rest of testimony

Brie Stotler Fri, 03/1/19 - 21:38 I strongly oppose this rule change. Banning the feeding of birds in the parks will adversely affect their health, especially in the winter when food is scarce. Many bird species frequent the bird feeders and many New Yorkers frequent the feeders to watch them. The rat population can be controlled by the birds of prey that frequent the parks or through the introduction of other natural predators. I encourage the city to investigate alternate solutions to the rat population problem.