HomeMy WebLinkAboutGarner, L DEIS.pdf KecelVed
Village of Cayuga Helghts
`'E'er 1 l 2010
Comment on DEIS for Cayuga Heights' Deer
Manaaement Plan
Submitted by:
Lowell Garner
10 Pembroke Lane
Ithaca, NY
To:
Kate Supron, Mayor, Village of Cayuga Heights
836 Hanshaw Rd.
Ithaca, NY 14850
December 16, 2010
Comment on DEIS for Cayuga Heights' Deer Management Plan
(CHDEIS)
My comments will draw from my practice of medicine of 25 years, educational
background and most recently course work at Cornell University in landscape
architecture, plant science and integrative pest management. The major source
for supportive information will derive from the National Park Service Rock Creek
White-Tailed Deer Management Plan DEIS (NPS) completed July 2009 that has
detailed references.
http //parkplannina nps gov/showFile cfm?proiectlD=14330&docTVpe=public&MI
METype=application%252Fpdf&filename=ROCR%2DDeer%2DDEIS%2DJuly%5
F2009sm%2Epdf&clientFilename=ROCR%2DDeer%2DDEIS%2DJuly%5F2009s
m%2Epdf
Overall, it is my assertion that the CHDEIS has not met the standards required
under NY SEQR process particularly in the presentation of accurate data
supportive of its conclusions. The format I will use to support this is as follows:
I will bold the page in the CHDEIS when the topic I take issue with first appears.
The specific statement will be placed in italics, followed by a 'Comment' section
that includes personal knowledge as well as referenced sources. Additional
pages in the CHDEIS that are later mentioned, which allude to the same topic,
will be discussed in this section. This may be followed by further commentary as
it relate to the NPS document mentioned above. I have made every attempt to
restrict my comments to the CHDEIS.
Pg1-1 of the CHDEIS:
...A study committee was subsequently formed with a view towards reducing the
deer population. Efforts were made at deer sterilization in the early 2000s, but
ultimately did not result in long term herd reduction.
Comment: The Cayuga Heights plan acknowledges that sterilization appeared to
work. It is an acknowledged fact that faulty serum was used as followup so that
there was ultimate failure of the contraceptive approach (stated clearly on pg 2-6
of CHDEIS: "...that study, a two year research trial (using surgical sterilization by
tubal ligation) was undertaken in the Village and that did reduce the size of the
deer herd. That study morphed into a year of contraception, which failed in 2005
due to a faulty vaccine."The misinformation that contraceptive modalities have
repeatedly failed has been repeatedly stated to buttress arguments for lethal
management of deer. Tubal ligation is permanent and is 100% effective.
Because tubal ligation is non-lethal (except in cases of perioperative mortality) it
would be acceptable to most who object to lethal means. It more than likely
would require a phased—in plan approach, which is already part of the CHDEIS.
Because Cornell has probably one of the biggest experiences in the country on
this, there is no reason not to pursue this further. Although twice the cost, it
remains as effective as killing. Control of fertility is constantly evolving and no
provision in the CHDEIS is included to continually reassess this option.
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From the NPS:
APPENDIX C. REVIEW OF WHITE-TAILED DEER FERTILITY CONTROL
...The use of reproductive control in wildlife management has been assessed for several decades.
Its use has gained more attention, as the public has become more involved in wildlife
management decisions. Interest in reproductive control as an innovative alternative to traditional
management methods, has led to the current state of the science(Baker et al. 2004). Often, the
use of reproductive control is promoted in urban and suburban areas where traditional
management tools, such as hunting, are publicly unacceptable or illegal due to firearm restrictions
(Kilpatrick and Walter 1997; Muller, Warmen, and Evans 1997)
CURRENT TECHNOLOGY
The area of wildlife contraception is constantly evolving as new technologies are developed and
tested...
IMMUNOCONTRACEPTIVES
...Curtis et al. (2002)demonstrated approximately 85-90% efficacy for both GnRH and PZP
immunocontraceptive vaccines in white-tailed deer. Over a 13-year period on Assateague Island
National Seashore, contraceptive efficacy in PZP-treated horses ranged from 92 to 100%
(Kirkpatrick and Turner 2008).
NON-IMMUNOLOGICAL REPRODUCTIVE CONTROL METHODS
...Leuprolide acetate: Leuprolide is one GnRH agonist that has been studied. Tests reveal that
when it is administered as a controlled-release formulation, it results in 100% pregnancy
prevention in treated female elk and mule deer(Baker et al. 2002, 2004, Conner et al. 2007). In
addition,the treatment is reversible, and the effects last only for a specific period of time (90-120
days)(Baker et al. 2004;Trigg et al. 2001). Advantages of leuprolide acetate are that it is 100%
effective in preventing pregnancy, is safe for human consumption (Baker et al. 2004), can be
delivered remotely(Baker et al. 2005), does not result in physiological side effects, and short-
term behavioral effects are minimal (Conner et al. 2007).
... Surgical sterilization is an invasive procedure generally performed on females. Successful
implementation is generally 100% effective in preventing pregnancy and this method is
common in managing domestic animal fertility.... Conditions that may contribute to successful
use of sterilization to reduce abundant deer populations include small population size and
demographic closure(or nearly so) (Merrill et al. 2006).
Pg1-1 of the CHDEIS:
At the present time, the estimated population of deer in the 1.8 square mile
Village of Cayuga Heights ranges between 160 and 200.
Comment: On page 68 of CHDEIS Appendix A Professor Paul Curtis asserts
"The last reliable population estimate I conducted for the deer herd in the Village of
Cayuga Heights was in the spring of 2006." This again is cited on page 1-7 of the
CHDEIS. I believe this is now the Winter of 2010- 4 years later. We have no idea
what the current population is. It is well known that deer populations can fluctuate
significantly due to environmental conditions such as food availability (e.g.
acorns) and weather. To assume a 10% rise per year (and his letter states just
that apparently based on a single data point of a 7% increase from 2005 to
2006), it can only be conjecture at best.
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From the NPS: I took the data from Rock Creek below and calculated the %
variation from year to year of seven data points. Which single point should we
have used below to have estimated the future deer population?
TABLE 2. DISTANCE SAMPLING RESULTS IN ROCK CREEK PARK calculated
Year Deer per Square Mile Standard Error of the Mean(t) %var.YTY
2000 62 11.6 NA
2001 63 6.9 1.6
2002 60 8.0 -5.0
2003 98 17.3 63.3
2004 75 7.8 -23.5
2005 52 6.9 -30.6
2006 58 8.9 11.5
2007 82 10.21 41.4
Source:K. Ferebee pers comm.2007b,2008f
Had we chosen 3 of the years (2002,2004,2005) no action would have been
even warranted! It is clear depending what year was chosen for examination, this
would have critically influenced the preferred plan. This same comment is
applicable to remarks on pg1-7 "...based on projections by the DRAC", which
continues to use Dr. Curtis' best 'guess'.
Pg1-2 of the CHDEIS:
...water contamination through substantially higher levels of untreated
wastes in stormwater runoff.
Comment: This is conjecture only and nowhere in the CHDEIS is this
contamination documented. Page 3-4 of the CHDEIS reasserts this conjecture.
No mention of fecal waste contamination ever appears in the entire NPS
document although it talks about stormwater and surface water repeatedly.
Historically, the Village has been careless in its duty to protect the watershed for
other causes. It therefore surprises me in light of these prior experiences that the
Village cannot supply more information.
Pg1-2 of the CHDEIS:
... It is expected that this program will, once implemented, result in a reduced
and stable deer herd in approximately three to five years.
Comment: No data has been supplied to support this assertion.
Pg1-4 of the CHDEIS:
...The smaller deer population will likely reduce deer/car accidents
Comment: there is no data provided in this report as to the traveling speed of
vehicles involved in deer collisions. In data that includes this variable, on average
85% of vehicles are traveling 35mph of more. The Village speed limit is 30mph.
Enforcement of the Village speed limit will not only result in fewer collisions but
also enhance pedestrian, bicycle, and domestic and wild animal safety. The table
below in Appendix D supports the contention that the roads at highest risk for
4
speeding in Cayuga Heights also have the most accidents. Page 3-3 of the
CHDEIS restates this point without pointing out the deficiency of this observation.
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Pg1-4 of the CHDEIS:
...It is expected that in the long term, local vegetative diversity and wildlife habitat
will improve...
Comment: The word 'expected', without the performance of controlled exclosure
experiments for a suburban landscape, is wishful at best, considering that
surface water runoff from suburban landscape is known to contain significant
herbicidal loads.
Pg1-4 of the CHIDES:
...Culling activities are likely to involve the discharge of firearms in the VCH. Mr.
Anthony Denicola, the owner of a firm that carries out deer culling activities,
advises that in 15 years of such work and the culling of some 9,000 to 10,000
deer, there has never been an incident of harm to people, nontarget animals or
property in connection with said activities (personal communication, 9128110)...
Comment: Mr. DeNicola stands to benefit significantly in both recognition and
financially as a private consultant if this plan goes forward (although it may not be
obvious since White Buffalo, Inc. is currently seeking tax exempt status as a
public charity according to its own website). To not corroborate his statistics of
'no incidents', is abandonment of responsibility by the government body that is
supposed to protect its electorate. Has a search been done to see if any civil or
statutory actions have been taken against him or White Buffalo, Inc? Have
organizations been contacted that have utilized his services to see if any
untoward outcomes have been associated with lethal action? "No record of
incidents" is by his account. In fact, I contacted the Kansas Department of
Wildlife and Parks after reading about an incident, which possibly could disturb
some public officials, should they consider hiring him. I was told they keep no
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such records. There are no national clearinghouses that even keep these
statistics; some states do (e.g. NY) and some don't.
Pg1-5 of the CHDEIS:
...While the culling of deer, as proposed by the Village, may be experienced as a
potential significant impact to the social conscience of a portion of the VCH
community...
Comment: The lethal option introduced (not mentioned publicly prior to the
CHDEIS), to be done in conjunction with sterilization, is trapping and use of a
penetrating bolt, sometimes referred to as netting and bolting. This lethal method
will not only create greater public dissent due its brutality but will amplify
neighbor-to neighbor conflict due to significantly less property restrictions of
where the technique will be permitted. No 500' sign-off is required. This will place
a burden on the community as well as public safety departments. This is
evidenced by the fact that a Freedom of Information request was necessary to
find out that net-and-bolt was being considered as late in the EIS process as 2
weeks ago. Clearly they did not want the community to have a chance to dissent.
Pg1-5 of the CHDEIS:
...The result of a successful sterilization and culling program will be a stabilized
deer herd of approximately 30 animals.
Comment: This statement assumes that Cayuga Heights is essentially an
exclosure, which it is not.
Pg1-6 of the CHDEIS:
...No significant unavoidable adverse impacts have been identified in connection
with the proposed deer management plan....
Comment: One of the major purposes of a DEIS is to present all possible
alternatives to determine whether or not a particular alternative imposes a
significant adverse impact that could be avoided. There is ample evidence that
lethal methods will produce significant community resistance. The NIPS
document has a whole section devoted to this. Specifically it states:"...There may
be some unavoidable adverse effects to visitors relating to the implementation of the
sharpshooting or capture and euthanasia, if the visitors happened to be near areas where this was
occurring and were disturbed by these actions."
Pg1-6 of the CHDEIS:
... lack of food will either result in wasting disease or result in increased deer
population in areas outside the VCH...
Comment: This misinformed statement's purpose is to confuse the lay
expression "wasting disease" with Chronic Wasting Disease, which is clearly
implied above to be due to lack of food, rather than a transmissible disease
(spongiform encephalitis), which has yet to be documented in our area as well as
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to cause additional public concern. As for preventing an increased deer
population in outside communities, this was never a stated in the CHDEIS as an
objective. In fact, the successful outcome of the CHDEIS is directly dependent
upon the assumption that Cayuga Heights is a relatively closed system- you can't
have it both ways.
Pg1-8 of the CHDEIS:
...This is the most cost effective method of reducing the size of the deer herd...
Comment: Nowhere in the CHDEIS is an "apples-to-apples" cost-benefit analysis
provided taking into account preparatory, implementation, and outcome phase
costs. To assert this without and actual accounting, is an uncertain statement at
the very least and very possibly quite erroneous at the worst. (see NIPS page 65
for an example of such a comparison; many such examples appear throughout
the document so their summary conclusions have data to support them). Pages
3-9 through 3-10 of the CHDEIS devote a discussion to socioeconomic
considerations and offer no CH data other than its annual budget. Pages 4-6
through 4-7, a section dedicated to analysis, offers nothing more than "it is
possible that the costs associated with the high density deer population
(ecological damage, vehicular accidents, tick borne diseases, landscape loss,
etc.), as discussed in Chapter 3 will be substantially reduced as well." The
expression 'It is possible' is not an acceptable conclusion to embark upon a plan
in this time of fiscal triage.
Pg 2-4 of the CHDEIS:
...Cayuga Heights is not a forest but rather an ecosystem heavily influenced by a
pattern of residential development and an associated suburban landscape. Ideal
deer population densities are likely different in the suburban setting than an
undeveloped forest...
Comment: The CHDEIS repeatedly supports its plan with historical and current
data that utilize the forest ecosystems as its gold standard. To use this data as
assumptions for suburban Cayuga Heights, as its own DEIS admits, can be
nothing less than suspect.
Pg 3-3 of the CHDEIS:
...These areas are important aesthetically in the Village, contain old growth forest
and hold other valuable ecological characteristics. They provide habitat to the
local deer herd. The impact of browsing on these natural areas is not known...
Comment: One of the key points in making the case for deer population control is
the loss of biodiversity. Here we have a forested "control" as part of the Village,
to use in conjunction with data from many other forested deer population control
plans throughout the U.S. and have the opportunity to determine comparability to
our region (let alone a suburban environment which they are attempting to
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compare a forest to), and no attempt has even been made! This is a glaring
oversight.
Pg 3-3 of the CHDEIS:
...It is not known how many people support the plan of the Village versus how
many people oppose it...
Comment: Because trapping and penetrating bolt gun is the desired lethal means
and only recently announced 2 weeks ago, the Village resident survey done in
the 1990's is not applicable. Many of the public are still unaware of the
implications of net-and-bolt and have not been surveyed as to their views. This
has the potential to mobilize a significant objection from the community with
public safety becoming even more of an issue than frangible bullets (besides the
simple fact that a majority of the community may be against the action, and the
fact that the Village board has repeatedly stated that they are acting at the
wishes of their community). The lack of recognition for the possibility of intense
community opposition as indicated on page 4-6 of the CHDEIS, has led to the
gross underestimation of allocation of personnel and money to the CH police, of
the effect on public safety, and of the costs of a probable legal challenge.
Pg 6-1 of the CHDEIS:
6.1 No Action Alternative
Under this alternative, no management of the deer herd would take place. The
DRAC has determined that No Action will result in continued growth of the deer herd.
Given the complaints about the deer population and the ongoing impacts of
ecological damage, deer/vehicle incidents, landscape destruction and tick borne
diseases, the No Action alternative will simply exacerbate the current situation.
It is possible that if the herd grows significantly, lack of food will either result in
wasting disease or result in increased density of the deer population outside the
VCH. If the No Action alternative is selected, certain activities associated with
sterilization and culling as identified earlier in this DEIS will not occur. While the
costs of the deer management program would not be expended from the Village
budget, the ongoing costs of ecological damage, vehicular accidents, landscape loss
and replacement and Lyme disease treatment would remain similar to existing
conditions or potentially increase as the density of the herd increases. The No Action
alternative would likely have far more adverse impact than the proposed action.
Comment: The whole purpose of the CHDEIS from its inception was to reject this
alternative. The assertions within this statement have been previously
commented upon in my aforementioned comments, and are generally
unsubstantiated.
Pg 6-1 of the CHDEIS:
6.2 Sterilization Only. No Culling
Under this alternative, no culling would take place and greater numbers of deer
would need to be sterilized in order to stabilize the herd at the numbers
recommended by the DRAC. This option is slower and more expensive than
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culling alone or the combined approach of culling and sterilization. It would take
three to five years to stabilize the herd, and herd reduction would not be evident
for five to six years, based on projections by the DRAC.
Comment: Once again, unsupported projections of population control are
asserted to dismiss this as an option. As presented previously, tubal ligation
combined with pharmocologic or immunologic contraception might provide a
more effective method that would produce earlier stabilization of population
density.
Pg 6-2 of the CHDEIS:
6.3 Firearm Culling Only, No Sterilization
This is the most cost effective method (in the short-term) to reduce deer herd and
also the most controversial...
Comment: It is not the most controversial. See the next section. Of particular
note is that sterilization was not combined with this technique to make this an
unacceptable alternative, as emphasized by "in the short-term".
Pg 6-2 of the CHDEIS:
6.4 Sterilization and Culling by Trapping
At the present time, trapping and killing deer is not permitted under the wildlife
regulations of the State of New York. However, if relief could be secured from
that provision via the deer management permit, an alternative to using firearms to
cull deer would be to trap deer and use a captive bolt gun. This device kills the
animal instantly allegedly without causing pain. A captive bolt gun has a steel bolt
that is powered by either compressed air or a blank cartridge. The bolt is driven
into the animal's brain. It has the same effect on the animal as a firearm with a
live bullet. A captive bolt gun is safer than a firearm and is considered to be an
effective form of euthanasia by the American Veterinarian Medical Association.
This is a slower process than culling and more labor intensive. Multiple traps
could be employed and deer could be culled over an extended period with minor
disruption to the local community.
Comment: Firstly this alternative is misrepresented by the title of the section,
perhaps giving the reader the impression that trapping will be combined with
translocation. This is not the case. Rocket-assisted nets are typically combined
with a penetrating bolt gun (used in the slaughter industry) to kill the animal. The
following are comments I presented at the Village meeting of 12/6/10:
The net and bolt technique outside of a slaughterhouse 1) lacks ways to
minimize fear of the condemned animals. There is mainstream
neuropharmacology supporting the assertion that fear and stress, not pain, are
the most inhumane of all stimuli we can inflict upon an animal. Temple Grandin
has written extensively on this subject. Even those who earn their living by
eliminating deer speak about the increased stress the animals experience with
the net and bolt technique. Netted deer will agonize from the most severe form of
9
fear. I can't emphasize this enough. From the time the deer are netted until they
are killed these animals will suffer; 2) lacks effective and predictable restraint- the
key to killing swiftly is an effective restraint, otherwise there are too many 2nd
attempts. A net does not provide effective restraint. There must be extreme
precision of bolt placement to effectuate a first-kill. A terrified struggling deer will
have its face frequently shattered before subsequent attempts are successful in
producing death; 3) lacks quick and accurate killing that minimizes pain making
the slaughter of these netted deer even more odious than any other technique
suggested until the present time. Though the bolt device is "effective" as a form
of euthanasia by the American Veterinary Medical Association Guidelines (as in
guidelines; not standard of care) on Euthanasia, the AVMA has never endorsed
this method as the preferred technique in the slaughter of whitetail deer.
To bring this point home further: It is "effective" to give cancer patients
intermittent pain medication to control suffering associated with their disease. It is
neither acceptable, desirable, suitable, adequate, applicable nor any other word
one might use. However, continuous administration of pain medication is
essentially the only method used today, and if it is not, there better be a
justifiable reason other than convenience. Those that make their living from
killing deer attest to the fact that net-and-bolt is the most stressful of all
techniques. In the NPS's final EIS document on Catoctin Mountain Park
http://www.nps.gov/cato/parkmgmtlloader.cfm?csModule=security/geffile&pageid
=127892 they emphasize this point.
Pg 7-1 of the CHDEIS:
...The labor and energy that will go into sterilization and culling activities will be
irreversible and irretrievable...
Comments: And "Irreversible and irretrievable" both in financial cost and life as
well.
General Comments:
1) There is potential for significant conflict of interest issues with respect to Drs.
Anthony DeNicola and Paul Curtis both individually and in collaboration with one
another. This id not disclosed in the CHDEIS and integrity demands this.
2) Throughout the CHDEIS there is mention of tick-borne disease and in
particular Lyme as a reason to pursue deer population control. Not in a single
sentence, in the entire 400 page NIPS EIS can one find mention of tick-deer
interaction as a reason to pursue deer population reduction (see below). The
CHDEIS page 2-10 assertion that "Studies also show that the number of ticks in
a local area is generally linearly correlated with the number of deer present.
Recommended mitigation of deer-borne diseases includes fencing, reducing tick
habitats... Educating the public includes practicing 'due diligence' in clothing for
outdoor wear and learning to check for ticks after being outdoors" have
disappointedly proven false time and again. All studies to date that have looked
10
at this, have supported the conclusion that reduction is helpful are quite isolated
systems or where other mammalian hosts other than deer are lacking. The single
paper (out of hundreds that show otherwise) cited in the CHDEIS on page 3-5
was an isolated offshore island that states clearly this fact. In a telephone
conversation (12/9/10) 1 had with Dan Sealy, Acting Chief of Natural Resources &
Science of the National Capital Region at the Center for Urban Ecology, he
stated in no uncertain terms, that the NPS never uses Lyme's incidence or tick
densities as threshold indicators for deer population intervention since there is no
correlation. Current medical literature on prevention recognizes this issue as well.
Gary P. Wormser, MD, from New York Medical College in Valhalla and an expert
on Lyme disease is caused by Borrelia burgdorferi, transmitted by the bite of the
tick species Ixodes scapularis and Ixodes pacificus has written extensively on
this (Wien Klin Wochenschr. 2005 Jun;117(11-12):385-91). He states: Deer
elimination or exclusion, application of topical acaricides to mice or deer, and application
of systemic acaricides to deer are more complex approaches. However, none of these
methods for reducing tick numbers, nor any of the recommended personal prevention
measures, such as reducing the amount of exposed skin, use of tick repellents on exposed
skin or clothing, and frequent tick checks to remove attached ticks expeditiously, has
been demonstrated to decrease significantly the incidence of Lyme borreliosis in humans.
It is also erroneous for CH to use countywide data (a rural region) to support its
contention that Lyme is a public health issue for its residents, as it does in
Appendix D of the CHDEIS, as well as to omit the travel histories of CH's
residents affected by this disease.
3) A glaring deficiency (pgs 2-7 through 2-10 which encompasses Specific
Recommendations) of this CHDEIS is that there is no provision or statement that
the plan's efficacy will be reviewed at periodic intervals to evaluate methods
currently in use in light of new concepts, especially non-lethal modalities. The
NIPS document emphasizes the importance of this point repeatedly. In addition,
there is no mention anywhere in the CHDEIS of adaptive management
considerations for any of the alternatives (NIPS page 73)
4) Frequent requests from the community, even those in favor of the lethal
alternative, have been made for 8' fencing- the village refuses to consider this an
option for individual property owners (see page 3-6 of CHDEIS) and it continues
to be ignored as an alternative in the CHDEIS.
5) One of the main intents for a DEIS is to invite interested stakeholders to
comment. There is no list of stakeholders in the CHDEIS other than mention of
the public and CayugaDeer.org. nor is there record of solicitation other than
public notice. The NIPS document contains a fairly large list, some of which could
be used to identify similar entities locally that would have an interest in this plan. I
have included the list below:
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LIST OF RECIPIENTS OF THE DRAFT PLAN ENVIRONMENTAL IMPACT
STATEMENT
This plan/EIS will be sent to the following agencies,organizations, and businesses, as well as to
other entities and individuals who requested a copy.
CONGRESSIONAL DELEGATES
Eleanor Holmes Norton, District of Columbia Delegate
Christopher Van Hollen,Jr., 8th Congressional District,Maryland
Donna F. Edwards,4th Congressional District,Maryland
Barbara Mikulski, U.S. Senate,MD
Benjamin L. Cardin,U.S. Senate,MD
FEDERAL AGENCIES
Chesapeake and Ohio Canal National Historic Park
Smithsonian National Zoo and National Zoo Police
State Department—Embassies
U.S. Department of Agriculture, Wildlife Services
U.S. Environmental Protection Agency
U.S. Geological Survey
U.S.Fish and Wildlife Service,Chesapeake Bay Field Office
U.S.Navy,Naval Observatory
U.S.Park Police
U.S. Secret Service
DISTRICT OF COLUMBIA AND LOCAL GOVERNMENTS
Advisory Neighborhood Commissions
Commission of Fine Arts
D.C. City Council
D.C.Department of Environment, Fisheries and Wildlife Division
D.C.Department of Health,Animal Disease Prevention Division
D.C. Department of Recreation,Office of Planning and Policy
D.C. Department of Transportation
D.C. Fire and Emergency Services
D.C. Historic Preservation Office, State Historic Preservation Officer
D.C. Metropolitan Police Department
D.C. Office Of Planning
D.C. Office of Tourism and Promotion
Maryland Department of Natural Resources, Wildlife and Heritage Service
Maryland National Capital Park and Planning Commission—Montgomery County
Metropolitan Washington Council of Governments
National Capital Park and Planning Commission
Washington Metropolitan Area Transit Authority
ORGANIZATIONS/OTHER
AAA Potomac
Adjacent Property Owners
American Automobile Association,National Office
American Recreation Coalition
Animal Welfare Institute
Arizona Bowhunters Association
Audubon Naturalist Society Central Atlantic States
Audubon Naturalist Society of the District of Columbia
Blair Road Garden Association
Chesapeake Bay Foundation, District of Columbia Office
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Chesapeake Bay Program Office,NPS
Chevy Chase Citizens Association
Crestwood Citizen's Association
Defenders of Wildlife
Earth Justice
Fort Reno Garden Association
Fort Stevens Garden Association
Friends of Animals
Friends of Montrose and Dumbarton Oaks Park
Friends of Peirce Mill
Friends of Rock Creeks Environment(FORCE)
Friends of the Earth
Glover Park Garden Association
Glover Park Citizens' Association
Golf Course Specialists Inc
Green Peace
Hillandale Citizens Association
Hillwood Museum
Humane Society of the United States
Interstate Commission of Potomac River Basin
Izaak Walton League of America
Jonathan Woodner C., Woodner Apts.
Mamie D.Lee Garden Association
Maryland Native Plant Society
Maryland Ornithological Society
Meadowbrook Riding Stables
Melvin Hazen Garden Association
National Park Foundation
National Parks and Conservation Association
National Wildlife Federation
National Zoological Park, Smithsonian
Nature Conservancy
Oak Hill Cemetery
Peabody Garden Association
People for the Ethical Treatment of Animals(PETA)
Potomac Appalachian Trail Club
Rock Creek Garden Association
Rollingwood Citizens Association
Sierra Club,DC Chapter
The Northwest Current
The Shoreham North
The Washington DC Examiner
Tilden Gardens
Trail Riders of Tomorrow(TROT)-50
Walter Reed Army Medical Center
Washington Area Bicycle Association
Washington City Paper
Washington Humane Society
Cayuga Heights is acting in apparent isolation in spite of a multitude of agencies
that may have a direct interest.
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Summary:
The CHDEIS in its present form does not specify the current deer density, does
not document the impact on biodiversity other than by stating the general
impressions of the public or by inference, does not acknowledge that Lyme
disease has no correlation to deer density in this open suburban setting, nor
does it allow placement of fences (exclosures). The Village has tried to
circumvent the EIS scoping process and comment by its introduction of the
alternative of trapping and use of a penetrating bolt gun by announcing its
preference for such, for the very first time, in this DEIS. In addition, the CHDEIS
represents a costly plan, one that is particularly inhumane and will pit neighbor
against neighbor Therefore, the CHDEIS should not be approved in its present
form and withdrawn.
Cornell University with its vast talent in ecology, horticulture and plant science,
veterinary medicine, and natural resources should help guide our decisions along
with all stakeholders. In an email I received today from the Acting Chief of
Natural Resources & Science of the National Capital Region at the Center for
Urban Ecology, Dan Sealy, he says, "I would encourage those working toward a
solution to make sure the goals of the effort are clear and achievable based upon
the best science you have available."
The CHDEIS goals while clear, may be poorly chosen, unachievable and at their
very best, based upon anecdote, questionable documentation, and lacking in
state-of-the-art science.
Respectfully submitted 12/16/10,
Lowell Garner
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