Like many New Yorkers, I’ve had fond experiences of feeding birds and squirrels in public parks. A proposed rule, which would amend § 1-04(g) of Chapter 1 of Title 56 of the Rules of the City of New York, would prohibit individuals “from feeding all animals, including squirrels, pigeons, and other birds, in areas under the jurisdiction of NYC Parks.” The New York City Department of Parks and Recreation, or DPR, is accepting public comments on the proposed rule from now until March 1. Additionally, a public hearing will take place on March 1, in Harlem. I cannot attend the hearing, and so I will be submitting a public comment. The following is what I plan to submit.

Under the Statement of Basis and Purpose of Proposed Rule there are many reasons cited, all of which don’t stand under scrutiny. I will go through each.

Reduce food sources available to rats and other rodents, which are attracted to all types of food in properties maintained by NYC Parks.

I fail to see how banning the feeding of birds and squirrels will make any significant impact on rats. The issue is garbage and littering around the city – including the parks – not feeding a nut to a squirrel or some bird seed to the pigeons. Let’s not scapegoat a minority of individuals, such as the elderly and children who visit the parks and may feed a bird, for what is a bigger problem relating to restaurants, food trucks, and litter. The best way to approach the rat problem is to address littering.

Prevent harmful interactions with animals in NYC Parks properties. Wildlife accustomed to feeding lose their wariness of humans and may exhibit aggressive behavior. Animals exhibiting aggressive behavior may then have to be lethally removed and tested for disease.

What statistical data is available to support this claim? I would like to see the data on squirrels, pigeons, and other birds who have attacked park goers. Individuals have been feeding wildlife in public parks for decades. If attacks were prevalent or on the rise because of the feeding then support the claim with data.

Support the efforts of New York City’s WildlifeNYC campaign to raise public awareness about urban wildlife.

I completely agree that we should be raising public awareness about urban wildlife. But why should prohibiting feeding birds and squirrels be a necessity to achieve this goal? So I disagree that awareness must include a prohibition on feeding birds. Instead, provide information such as what food should never be fed to birds, like bread.

Promote compliance with the New York State Department of Environmental Conservation’s guidance, which advises that wildlife feeding disturbs the healthy balance between wildlife populations and their habitats.

I’m not convinced that there is a healthy balance between wildlife populations and their habitats. Is there really enough food found naturally to sustain the squirrel and pigeon populations, for example? And with the environment being impacted by climate change, is there a cause for concern that wildlife cannot find enough sustenance?

Prevent the transmission of disease that occurs when animals congregate around feeding areas. In these areas, food may be contaminated with feces, saliva, and urine, promoting the spread of diseases. These diseases are often fatal to animal populations and some may be spread to humans. For example, a canine distemper outbreak recently led to the deaths over 300 raccoons in New York City’s parks.

While the raccoon deaths are unfortunate, this appears to be a non sequitur. A canine distemper outbreak has no relevance to a discussion on whether feeding birds or squirrels should be banned.

Support healthy wildlife nutrition and behavior. Food given to wildlife does not contain the nutrients needed by New York City’s wildlife and deters them from seeking the natural foods—like insects and plants—with nutrients they need. Young animals fed by park patrons may not develop properly and may lose the instincts needed (such as hunting and foraging) to survive on their own.

This is an issue of public awareness. Educate the public on what nutrients birds and squirrels may need and what food should never be fed to them.

Reduce the maintenance burden on NYC Parks staff responsible for maintaining a safe and clean environment for park patrons.

This seems to be related to the first claim about rats. A safe and clean environment should begin with addressing garbage and littering. Anecdotally, what I’ve seen in the parks is not related to anyone feeding wildlife but garbage cans that are overflowing and people who leave their trash behind. Additionally, I fail to see how feeding a squirrel makes the park not “safe.”

Promote compliance with existing prohibition on feeding in NYC Parks properties.

If there is already a rule, then why waste the time and money on this one?

Lastly, I would like to add a few more reasons why I oppose this rule. First, how will this be enforced? I find it unlikely that park staff will be punishing an elderly person, sitting on a park bench feeding a squirrel, with fines. Second, if there is concern for feral and stray cat populations in parks, then what we need to attack the issues specific to that matter: Trap, Neuter, Return; Spay and neuter availability and affordability for pet owners; and promoting pet adoption. Banning the feeding of squirrels and birds will not reduce feral cat population. Lastly, this proposed rule is too broad; for example, there are no exceptions for animal rescuers. Ultimately, it comes down to this: Are people who care about animals really those who we want to punish?

For the above reasons, I oppose this rule as it is written.

Male wood duck in Central Park. Photo by Rhododendrites [CC BY-SA 4.0 (https://creativecommons.org/licenses/by-sa/4.0)%5D

More information on how to submit comments or attend the public hearing, via the Washington Square Park blog:

• Submit comments to NYC Parks through the NYC rules website at http://rules.cityofnewyork.us.
• Email comments to rules@parks.nyc.gov.
• Mail comments to:
  Darci Frinquelli, Assistant Counsel
  The New York City Department of Parks & Recreation
  The Arsenal, Central Park
  830 Fifth Avenue
  New York, NY 10065
• Fax comments to 917-849-6742.
• Speak at the hearing.

INFORMATION FOR THE PUBLIC HEARING:

• WHEN: Friday, March 1st, 12 noon.
• WHERE: Pelham Fritz Recreation Center, 18 Mount Morris Park West between West 122nd Street and Mount Morris Park West, located in Marcus Garvey Park.
• Anyone who wants to comment on the proposed rule at the public hearing must sign up to speak.
• You can sign up before the hearing by calling Darci Frinquelli at 212-360-1383 or emailing rules@parks.nyc.gov.
• You can also sign up in the hearing room before the hearing begins on March 1 at noon.
• You can speak for up to three minutes.