HomeMy WebLinkAboutHauter, W DEIS.pdf 12-18-10;08:03PM; ;6072750702 # t/ 2
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Village of Cayuga Heights,New York
Deer Remediation Advisory Committee
Marcham Hall
836 Hanshaw Road
Ithaca,NY 14850
December 16,2010
Dear Madam or Sir:
The Village of Cayuga Heights has recently proposed an aggressive deer population control
program in response to an increased deer population. The proposal is justified in part by the
purported public health risk from runoff tainted with deer waste.)
I am the executive director of Food& Water Watch, a national consumer organization that
studies both municipal water systems and the impact of large livestock operations on the
environment. Food& Water Watch has written extensively on the damage that excessive animal
waste can have on local watersheds and the concomitant impact on clean municipal drinking
water.
Certainly animal waste can pose risks to drinking water supplies, but the slight risks posed by
waste from wild deer can be easily mitigated by less aggressive, less risky and less expensive
approaches than the net-and-bolt strategy currently favored by the Deer Remediation Advisory
Committee. .
First, the focus on deer as the key source of microbiological contamination risk may be
misplaced. It is far from clear that deer are the primary source of any runoff contamination.
Some localities have found that waterfowl were the primary source of wildlife waste runoff.2
Using U.S. Department of Agriculture data, Food& Water Watch recently reported that
Tompkins County contains nearly 3,600 dairy cows on the largest class of farms that produce
145 million pounds of untreated manure every year.;
Determining the existence and source of any manure or wildlife waste runoff must be the first
step in developing an appropriate policy to mitigate the risk of water contamination. The U.S.
Environmental Protection Agency recommends tracking the bacterial source of non-point
microbiological contamination before putting a plan in place.4 Inexpensive alternatives to assess
the source of any runoff pollution include antibiotic resistance analysis that can pinpoint the risk
from deer.5 Until native deer are determined to be the source of any waterborne bacteriological
f Cayuga Heights Deer Management Plan DEIS.November 1,2010,at Existing Conditions page 3-4.
1 US Environmental Protection Agency.National Management Measures Guidance to Control Nonpoint Source
Pollution from Urban Areas.EPA-841-B-05-004.November 2005,at 2-15.
s U.S.Environmental Protection Agency."Risk Assessment Evaluation for Concentrated Animal Feeding
Operations"EPA/600/R-04/042.May 2004 at 9.See Food&Water Watch."Factory Farm Nation."November
2010.
4 US Environmental Protection Agency.National Management Measures Guidance to Control Nonpotnt Source
Pollution from Urban Areas.EPA-841-B-05-004.November 2005,at 2-13.
s]bid.at2-15.
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contamination, it would be ill advised to pursue an expensive and dangerous program to limit the
deer population.
If wild native deer are determined to be the source of any runoff contamination,there are many
Iess expensive, less dangerous and more effective policies that can provide greater protection to
municipal water sources. The most effective strategies to reducing contamination from runoff are
to improve the grade, contour,buffer and foliage surrounding waterways to provide natural
filtration and reduce the speed of water runoff.
The New England Interstate Water Pollution Control Commission recommends habitat
modification(including landscape changes and tree branch pruning),preventing human feeding
of wildlife (especially waterfowl),monitoring wildlife populations in and around water supplies,
deterring wildlife from vulnerable watershed areas and reducing available food sources.6 These
strategies have the added advantage of addressing the extant deer population but also any future
deer that may enter the community and repopulate the area after any short-term deer population
control strategies.
There are a host of additional legitimate criticisms to the proposed strategy to control the native
deer population. The proposal includes a waiver from New York state rules to use"net-and-bolt"
methods that are usually banned because they are inhumane.?It would be expensive, intrusive
and potentially dangerous to local citizens and pets to deploy explosive nets within the village
residential areas. Short-term population control mechanisms over native deer only address the
current deer,not the long-term existence of whitetail deer in Western New York. Although the
current deer might be controlled,more deer will likely come to the village.
It is especially disingenuous to use the legitimate concern of water contamination to justify a
policy that is considerably more draconian than necessary to protect the village water supply.
There are a host of more affordable,more effective,and less dangerous and aggressive policies
to protect the village's water supply than the proposed net-and-bolt so-called strategy offered by
the Deer Remediation Advisory Committee. Stopping the spread of dangerous pathogens and
chemicals in our water is a legitimate concern for all governments. But using those concerns as a
scare tactic neither serves the people of Cayuga Heights nor protects the water resources of the
area.
Sincerely,
W
Wenonah Hauter
Executive Director
Food & Water Watch
6 New England Interstate Water Pollution Control Commission. What do you knoiv about microbial contamination?
Available online at http://www.neiwpce.oEg/whatdoyouknowabout.asp.Accessed December,2010.
r Cummings,Anne Marie."Deer control method sparks debate."Tomkins Weekly.November 22,2010.
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