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 New York’s Department of Environmental Conservation is currently taking public comments on its proposal to kill 2,200 mute swans by 2025. As you can imagine, there has been fierce opposition from many who enjoy seeing the beautiful animals in New York’s parks.

Wildlife experts rightly note that the state’s purported concerns about the swans being an invasive species are overblown – and that even if there are problems with the birds, the solution need not involve mass slaughter.

Which brings us to a topic that is the subject of substantially less public scrutiny, despite government oversight: cruelty to birds – 4 million times as many birds, in fact.

First, some background: In 1958, Congress passed the Humane Slaughter Act, to require animal welfare improvements in our nation’s slaughterhouses.

But in enforcing the law, the USDA chooses to exempt many animals – including fish, rabbits and birds, even though birds represent more than 8.8 billion of the 9 billion animals slaughtered annually in the United States.

That’s right: The agency charged with enforcing the Humane Slaughter Act refuses to apply it to more than 98% of slaughtered animals.

Because the USDA refuses to protect them, most birds in slaughterhouses are subjected to abuses that would warrant cruelty convictions under federal law if cows or pigs were the victims.

You really have to see poultry slaughter to believe it, but as just one example, USDA records indicate that almost a million chickens are boiled alive every year when they miss the neck-slicer and go, fully conscious, into the water bath that is used for feather removal.

Although no plant has yet gotten in trouble for boiling birds alive, the USDA has repeatedly recognized its own obligation to stop this horrible cruelty, because the abuse of birds leads to adulterated meat, in violation of the Poultry Products Inspection Act. In 2005, it published a notice in the Federal Register proclaiming that bird welfare is a “high priority” for its inspectors and detailing multiple ways in which ill treatment causes adulteration.

The government is legally obligated to ensure that cruelty-based adulteration is prevented, just like it works to ensure that other forms of adulteration are addressed. But, almost a decade after proclaiming its commitment to bird welfare, it has not produced a single regulation focused on that aim.