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HomeMy WebLinkAboutLaVeck, J; Stein J; Huang, E DEIS.pdf December 16, 2010 To: Cayuga Heights Mayor and Board of Trustees Comments on Cayuga Heights Deer Management Plan Draft Environmental Impact Statement (DEIS) Our names are Jenny Stein, James LaVeck and Eric Huang. We are all residents of Ithaca and we are offering our comments on the DEIS in our capacity as concerned citizens and on the basis of knowledge we have gained through our attendance at, and videotaping of, over 35 meetings of the Cayuga Heights Board of Trustees, all the public meetings of the Deer Remediation Advisory Commit- tee, all the SEQRA meetings regarding the deer issue, and every public forum held on the deer issue since the existence of a government-sponsored plan to kill most of the deer of Cayuga Heights came into public awareness in August of 2008. Since that time, we have attended meetings to observe, to record documentary footage, and to express our opposition to such a killing plan, which inspired us to found a citizen's group called CayugaDeer.org. By profession, we are documentary filmmakers and educators who specialize in subject matter related to the journey of awakening conscience and the ethics of the human-animal relationship. Issue #1: Request for correction of misinformation propagated by the Village government that significantly impacts the ability of the public to make accurate assessments of alternatives that may have less negative environmental impact than the proposed deer killing plan. At the October 28, 2009 public hearing held to solicit community feedback on the Draft Deer Reme- diation Plan, I, James LaVeck, spoke during the allotted time and then handed in to the trustees the document reproduced on the following pages, which is self-explanatory. Following submission of this document, through my start-to-finish attendance at every meeting of the trustees since that time, I was quite surprised not to see any evidence that the information put forth in this document was either investigated or acted upon by the trustees, or that steps were taken to correct the significant misinfor- mation that, in my opinion, was propagated amongst the public as a result of the situation described below. On August 25, 2010, 1 filed a Freedom of Information Law Request to assess the status of the con- cerns that I and many other citizens had submitted for the record, both orally and in writing, at the 10/28/09 SEQRA hearing. Once again, none of the many documents my videotape record showed being handed in to the trustees at this hearing were returned in response to this request, increasing my concern. Finally, on On November 12, 2010, through another Freedom of Information request, I resubmitted the document below and requested any documentation indicating that the information it brought to light had since been investigated or acted upon by the trustees. Once again, to my sur- prise, no such documents were returned by the village. Therefore, I am now bringing this matter to the attention of the trustees for the third time, and re- questing once again that they investigate the validity of this information. Should they confirm it to be accurate, I am requesting they take immediate action to correct the substantial and significant mis- information that has been propagated amongst the people of this community as a result, such propa- gation having occurred, for example, through a mailing sent out by the Deer Remediation Advisory Committee in March of 2009 summarizing various options for addressing deer-human conflict. I also hope that the trustees will take seriously the implications of this in terms of the validity of the informa- tion upon which their currently proposed plan is based. 1 originally submitted 10-28-09 at VCH SEQRA Hearing on Draft Deer Remediation Plan The SEQR process was created with the intent to facilitate informed decision making,and the clear requirement that decision makers take a"hard look" at alternatives with less environmental impact than the proposed plan of action.This requires access to qualified experts who can be trusted to supply accurate information about complex issues.When information offered by experts is misleading or inaccurate,the effect in the integrity of the decision-making process and especially the environmental review process can be devastating. As documented in video record, on November 20, 2008, Dr. Paul Curtis,a professor with Cornell University's Natural Resources Department, made a presentation at a public meeting of the Cayuga Heights Deer Remediation Advisory Committee (DRAG). During this presentation he discussed his previous involvement in a deer population reduction program in Cayuga Heights and offered his analysis of various options for addressing the Cayuga Heights trustees' desire to reduce the current population of deer in Cayuga Heights. During this presentation,which included projection of slides and photos, Dr. Curtis also answered questions from trustees, members of the DRAC,and members of the public. At the time of Dr. Curtis's presentation, members of the DRAC were comparing several potential methods of reducing the deer population in Cayuga Heights, including sterilization, immunocontraception, and killing. It was during his comments on the costs and efficacy of immunocontraception methods used successfully for two large scale management oriented deer contracepive projects, that Dr. Curtis made numerous statements whose accuracy has come under question.The numerous inaccuracies in Dr. Curtis's presentation had the cumulative effect of making it appear that the immunocontraception methods described for these two projects were grossly more expensive and grossly less effective than they have been documented to be in peer-reviewed publications that are quite well- known in the wildlife management field.These inaccuracies take on real significance in the context of Dr.Curtis's role as the principle scientific expert consulted by the trustees,and the central role played by Dr. Curtis's theories in the development of the trustee's proposed plan. In response to Dr. Curtis's remarks at this November 20, 2008 presentation,we have reviewed the published literature and have sent Dr. Curtis's remarks to Dr.Jay Kirkpatrick, one of the scientists who had significant involvement with both of the above mentioned deer contraceptive projects. We requested that Dr. Kirkpatrick respond to each remark. With some reluctance he agreed to do this with the understanding that he is not advocating any form of management at Cayuga Heights. As a condition for responding to these remarks,he also made it perfectly clear that, while he has no interest in the Cayuga Heights issues,he does have an interest in making clear that deer contraception has been successful and that the real issues are social, cultural,economic and political,but not scientific. We chose Dr. Kirkpatrick from among several scientists who could have done this review because of his extensive experience with wildlife contraception over a 40 year period. 2 Originally submitted 10-28-09 at VCH SEQRA Hearing on Draft Deer Remediation Plan If the scientific expert upon whose research, consultation and advice the trustees based their plan presented information this inaccurate about an alternative approach with a lower cost and lower environmental impact than the one the trustees adopted with Dr Curtis's advice, and if Cornell research programs connected to Dr. Curtis are slated to receive over$270,000 dollars of funding from the Village of Cayuga Heights under the plan he helped develop, are the trustees not obligated to reconsider their entire plan as well as question the validity of all claims made and information supplied by Dr. Curtis? James LaVeck City of Ithaca 3 Originally submitted 10-28-09 at VCH SEQRA Hearing on Draft Deer Remediation Plan Dr. Kirkpatric responds to representations made by Dr. Paul Curtis To whom it may concern: Below are excerpts from the video transcript of Dr. Curtis's 11-08 presentation to the Cayuga Heights Deer Remediation Advisory Committee. My comments on relevant transcript excerpts are in red, while Dr. Curtis's and other event participant's comments are in blue. Cayuga Heights Mayor Gilmore: In what communities has sterilization worked? Dr. Paul Curtis: Depends how you define "worked." Mayor Gilmore: Effectively, measurably lowered deer populations to tolerable levels? (Note: based on Dr. Curtis's reply, it is clear he understood Mayor Gilmore to be asking about immunocontraception, not sterilization) Dr. Curtis: None that I'm aware of. Okay, the two studies that are often touted as the [makes air quotes with his hands] "success stories" for immunocontraception are Fire Island National Seashore, out on Long Island —they've done an immunocontraception program out there with PZP for about 10 years, and they have suppressed the growth, the population growth has been lowered dramatically. Numbers, depending on how you look at the data, are maybe slightly down, but not a huge amount. Dr. Kirkpatrick comments:See Rutberg and Naugle, 2008. Population-level effects of immunocontraception in white-tailed deer. Wildl. Res. 35:494-501. This published paper reports on a 60+%decline in the deer population on Fire Island communities where immunocontraception has been used for 16 years, not ten years as Dr. Curtis stated. 60+ %is a "huge"amount by anyone's standard. Dr. Curtis: The way they census deer out there— I've got some questions on their numbers, they do browse, pellet surveys, and that whole method is questionable to start with —that's what they're using. Dr. Kirkpatrick comments: On the Fire Island project the population study work was carried out by Brian Underwood, of the USGS at Syracuse, using distance sampling methods, not the methods described by Dr. Curtis. Dr. Curtis: So, at least they suppressed the herd, but they haven't really reduced it. They've still got way more deer on the landscape than they want, after 10 years of the program and spending well over a million dollars out there. Dr. Kirkpatrick comments:Again, 60+ % reductions were documented in peer-reviewed 4 Originally submitted 10-28-09 at VCH SEQRA Hearing on Draft Deer Remediation Plan publications. No population goals were ever set for the Fire Island project, by the NPS or the Dept. of Commerce for a second project at the National Institute of Standards and Technology (NIST), in MD. . Who then, is the "they'Dr. Curtis referred to as having "way more deer on the landscape than they want?Certainly not the citizens of Fire Island National Sea Shore. The costs at the Fire Island Sea Shore Project, which 1 directly tracked myself for the first two years of the project('93 and '94), never exceeded $10,000 for each year. There is simply no factual basis that a million dollars was spent. Dr. Curtis: The other place they cite as a success is the National Institute of Technology and Standards [sic] down in Virginia [sic]. There's a semi-captive herd in fence, again PZP [on immunocontroception vaccine used by Dr. Kirkpatrick]was used for many years. There's actually some relatively good data, the deer numbers were reduced a bit there. But again, there's still more than the goal density. Mayor Gilmore: They're fenced in? Dr. Curtis: They're—at least part of the facility is fenced. Mayor Gilmore: Part of it. Audience member: Where was that? Dr. Curtis: The National Institute of Technology and Standards. I think it's Front Royal, Virginia. Dr. Kirkpatrick comments: NIST is located in Gaithersburg, MD, about 90 miles from Front Royal. It is the typical urban deer situation, with highways, dense residential areas and continued commercial development surrounding it. The herd at NIST can leave or enter the facility at will through the many gates. One buck, for example, showed up at Dulles Airport, 40 miles away. Hence, in this context, the use of the term semi-captive is extremely misleading. The use of this term ignores fundamental white-tail deer social organization and behavior. These animals live in matriarchal family units and if they are not harassed and adequate nutrition is available, will spend their entire lives in a one- half to one square mile area. But their doing so does not make them 'semi-captive'. Deer Committee Chair Kate Supron: What's the life expectancy of a doe, if they're not hit by a car? Dr. Curtis: At least 12 years, some will get a little bit older. So that's, again, why we don't see the immunocontraceptive vaccine as being a good solution, because that means we're going to have to handle that deer six or eight times in her lifetime — minimum --to shut down her reproduction. That's why you're better off doing the spay the first time and not have to worry about it for 12 years. 5 Originally submitted 10-28-09 at VCH SEQRA Hearing on Draft Deer Remediation Plan Dr. Kirkpatrick comments: Immunocontraception was developed with a goal of no handling of the animals, for ethical reasons. An animal can be darted six or eight times in her life without capturing her. This issue, of handling, or no handling is an animal welfare issue and not a scientific one. Kate Supron: And when —at what age do they breed, and for how long? Dr. Curtis: It's variable. Depends on — it depends on quality of habitat. So where you've got a really good quality of habitat here, some of the earlier born female fawns— maybe as many as 20% of the earlier born female fawns—will breed as fawns. Invariably almost all the yearling deer—the year-and-a-half-old deer—will breed, and usually most yearling deer will have a single fawn the first birth. And then once a deer is two-and-a- half years old or older, and a full doe, then she will typically have two fawns every year for the rest of her life. And occasionally, when resources are real good, the winters are mild, she may have three. We occasionally see triplets. So, if you start looking again at the population growth equation, you've got annual first breed —fawns or yearlings for the most part. You've got a long-lived animal that's going to live 12 years, and so to keep the population stable, for a 12-year-old female deer, only one of her female fawns needs to survive during her lifetime in order to keep the population stable. And what are the chances of that? Not very good. Dr. Curtis: So what have we learned from immunocontraception? Both the vaccines effectively inhibit reproduction for individual deer. They're very costly, given the field protocols you gotta do. Dr. Kirkpatrick comments:The immunocontraceptive costs $24/dose (the cost of production); $2.15 for the dart; fifty cents for the adjuvant. Labor is the only other significant cost. Dr. Allen Rutberg, at Tufts University School of veterinary Medicine and the lead author in the scientific publications describing these two projects, did an exhaustive analysis of labor for deer contraception. Contraceptive darting time per deer ranges from lows of 2.7 -to highs of 17 hrs per deer. If you use an average of about 10 hrs per deer, and you want to treat about 100 deer, and you pay the darter $15/hr, the cost is about $15,000 per 100 deer, which is somewhere in the neighborhood of what we found at Fire Island (except the time per deer was lower there). (see Rutberg. 2005. Deer contraception; What we know and what we don't know. Humane Wildlife Solutions. A. Rutberg led). Humane Society Press, Washington DC, Pp. 23-42). Dr. Curtis: And a couple of other things we saw—with the PZP vaccine, because the female deer weren't becoming pregnant, we saw a lot of increased activity. The buck continued to try to breed those deer up until March, when photoperiods shut down their estrus cycling. Normally with deer--typically the majority of adult does would get pregnant right on their first estrus in November—first week in November is about the 6 Originally submitted 10-28-09 at VCH SEQRA Hearing on Draft Deer Remediation Plan peak around here. For those does that don't become pregnant on the first breed, they'll cycle again in December, and most of the does at that point will get pregnant and conceive on their second breeding. And then usually by the time that you're at the end of December, there aren't any fertile does left. But with the PZP-treated female, because they can't become fertile, photoperiod keeps that cycling going. And so they cycle based on day length, and they cycle again in January, and they cycle again in February, they cycle again in March. So you've got bucks chasing does all winter long, that you wouldn't normally have. So that could mean potentially deer running in front of cars. We know most deer-vehicle accidents occur during the peak of the rut in November. There's good data that show that. And a lot of these things need to be looked at, I think, if we're going to get into using these vaccines in a management phase over the long term. Dr. Kirkpatrick comments:The study referred to here was done at Front Royal, at the Smithsonian's Conservation and Research Center (see McShea et al. 1997. The effect of immunocontraception on behavior and reproduction of white-tailed deer. J. Wildl. Manage. 61:560-569.) What was discovered was that (1) treated deer did extend their breeding season, (2) older bucks did all the normal early breeding and then quit, (3) younger bucks (spikes and fork horns) followed the estrous does around but not in any form of frenzy, (4) the following summer, the non-pregnant treated does were significantly heavier than the non-treated does with fawns. A subsequent study showed that by fall, weight differences disappeared (see Walter et al. 2003. J. Wildl.Manage. 67:762-766). The point here is, that a "frenzy" of activity does not result from the extended breeding season. And in fact, there is published data to show that, in treated populations (NIST in this case) deer-car accidents decline as population declines. (see Rutberg and Naugle 2008. Human-Wildlife Confliects 2:60-67.) If immunocontraception and the extended breeding season resulted in more car-deer collisions, why did the rate go down at NIST? End of video transcript excerpts/comments Jay F. Kirkpatrick, Ph.D. Director The Science and Conservation Center 2100 South Shiloh Road Billings, MT 59106 406-652-9719 fax (406) 652-9281 j ki rkpatrick@ montana.net 7 Originally submitted 10-28-09 at VCH SEQRA Hearing on Draft Deer Remediation Plan Biography of Jay F. Kirkpatrick, Ph.D. Dr. Kirkpatrick grew up in rural Bucks County, Pennsylvania and earned the Ph. D. in reproductive physiology from the College of Veterinary Medicine at Cornell University in 1971. For 23 years he taught physiology at Montana State University-Billings and for seven of those years he served as Dean of the School of Arts and Sciences. Along the way of this career Dr. Kirkpatrick worked as a ranger for the National Park Service for seven years, in Rocky Mountain National Park, was a senior scientist for Deaconess Research Institute, and carried out post-doctoral studies at the veterinary schools at the University of Pennsylvania and the University of California at Davis, and at the Center for Reproduction in Endangered Species at the San Diego Zoo. He also held an academic appointment as adjunct associate professor in the Department of Population Health and Reproduction, School of Veterinary Medicine, University of California at Davis from 1992 to 2005, and is currently the Director of the Science and Conservation Center at ZooMontana, in Billings. Dr. Kirkpatrick has served on the National Animal Damage Control Advisory Committee for the Secretary of Agriculture. He is a member of the Contraceptive Advisory Group for the Association of Zoos and Aquariums, and has served on the Montana Wolf Management Council. For the past 38 years Dr. Kirkpatrick has carried out research on fertility control for wild horses and other wildlife,for the purpose of developing non-lethal and humane methods of controlling wildlife populations, and on non-capture methods for studying reproduction in free-ranging wildlife species through the use of urinary and fecal steroid hormones. His work has included wild horses, African elephants, white-tailed deer, water buffalo, bison,elk and more than 100 species of captive exotic animals in zoos. Dr. Kirkpatrick is probably best known for his contraceptive research with the wild horses of Assateague Island,for the study of reproduction in the bison of Yellowstone National Park, and more recently for African elephant contraception in the Republic of South Africa. He is the author of more than 100 scientific papers and book chapters, of which 54 relate to the biology of wild horses or fertility control of this species. He is also the author of Into The Wind: North America's Wild Horses. In 2001, the reproductive biology laboratory of the new veterinary center for Kruger National Park, in South Africa was dedicated in his name. In 2002, he was the recipient of the National Park Service's Researcher of the Year for the Northeast Region,for his contraceptive work with the Assateague wild horses, in 2004 he was awarded the Montana Academy of Science's Mershon Award,for outstanding contributions in the field of science in Montana, and in 2005, Dr. Kirkpatrick was inducted into the Wild Horse and Burro Exposition Hall of Fame. He is best summarized by a comment by Dr. Ron Keiper, Distinguished Professor of Biology at Penn State University, himself a noted wild horse researcher. He says, "Dr. Kirkpatrick is a champion of wild horses. To their cause he has brought the cold eye of 8 Originally submitted 10-28-09 at VCH SEQRA Hearing on Draft Deer Remediation Plan science and the warm heart of compassion. To him wild horses have value simply because they are magnificent creatures that have survived all that nature and man has thrown at them." Dr. Kirkpatrick lives with his wife Kathie in Billings, Montana, with their two dogs Angus and Farley and cat Savannah. 9 Issue #2: Request for description of the action (deer killing program) sufficiently detailed for the public to evaluate the environmental impacts that will result Cayuga Heights' Deer Management Plan DEIS Executive Summary: page 1-5 puts forth a budget of $750,000 over the course of the first five years of the deer killing plan. While carrying out calculations about the cost of the mass killing of deer is in itself disturbing, based on the claimed current level of deer population of 160-200, the target population number of 30, and the estimated figures given for the costs of either sterilizing ($1,100 each) or killing ($500 each) deer, along with a generous allow- ance for the cost of killing deer immigrating in from other municipalities after most of the deer are killed in the Village, it appears that no more than roughly $150,000 to $250,000 could conceivably be needed to carry out these activities, leaving $500,000 - $600,000 of the total budget allocated to 1) contingencies, 2) the salary of a "deer management director", and 3) an item described as "modeling/ tracking study."A"Draft Plan Cost Analysis" document developed by the Village government and ob- tained through an October 15, 2009 Freedom of Information request, included two years of salary for a deer management director at $30,000 per year. Factoring this in, between $440,000 and $560,000 of the $750,000 put forth in the DEIS will be left to cover contingencies and an item described as a "modeling/tracking study." Based on the Draft Plan Cost Analysis document, the "modeling/tracking study" is an activity for which $275,000 is budgeted over the 10 years of the projected plan, of which $225,000 would be expended in the first five years. According to statements made by Trustee Robert Andolina at an 8/24/09 meeting, these funds are budgeted to pay a "PhD from Cornell" to carry out these vaguely specified duties. "Draft Plan Cast Analysis"for Cavuga Heights'deer management progrcun. received through 10/l 5109 Freedom of In/ornmtion Request 2010 2011 2012 2013 ,.2014 _ .. 2015 2016 2017 2018 2019 Sterilized Deer $ 36,000.00 $ 3,600,00 $ 3,600.00 $ 3,600.00 5 3,600.00 $ - $ - $ - $ - $ Culled Deer $ - $ 70,000.00 $ - $ - $ - $ - $ - $ - $ - $ Deer Management Professional $ 30,000.00 $ 30,W0.00 $ - $ - $ - $ - $ - $ - $ - $ - Modeling/Tracking/Study $ 50,0W00 $ 50,OOOW $ 50,000.00 $ 50,W0.00 $ 25,000,00 $ 10,W0.00 $ 10,00000 $ 10W0.00 $ 10W0.00 $ 10,000.00 Contingency $ 50,OD000 $ 50,000.00 5 50,0W.00 5 SO,W0.00 $ 50,000.00 $ 10,000.00 $ 10W0.00 $ 10,000.00 $ 10,00000 $ 10,000.00 Indirect Cost Rate(CAB) $ 12,900,00 $ 8,040.00 $ 8,040,00 $ 8,040.0 $ 4,290.W $ 1,500.W $ 1,500.00 $ 1,500.00 $ 1,50000 $ 1,500,00 Total Program $ 178,900,00 $ 211,640.00 $ 121,640.00 $ 111,64000 $ 82,990.W $ 21,500.00 $ 21,500M $ 21,500,00 $ 21,5W.00 $ 21,500.W PV Program $ 804,210,00 0.00% Sterilized Deer 30 3 3 3 3 0 0 0 0 0 Culled Deer 0 140 0 0 0 0 0 0 0 0 Cost to sterilize per deer $ 1,200.00 $ 1,200.00 $ 1,20000 $ 1,200.W $ 1,200.00 $ 1,200,00 $ 1,200.00 $ 1,200.00 $ 1,200.W $ 1,200.00 Cost to cull per deer $ 500.00 $ 500.00 $ 500.00 $ 500 W $ SW.00 $ 5W.00 $ 500.00 $ 500.00 $ 500.00 $ 500,00 CATS Research Indirect Charge 15% In order for the public to be able to evaluate the potential environmental impact of an action, the description of the action offered must be of sufficient detail for us to be able to clearly understand what sort of activities will be carried out in the community, where and when they will be carried out, by whom, and for what purpose. As the DEIS is written, this information is completely omitted for activi- ties substantial enough to comprise 30% of the project's budget. Further, in a July 16, 2009 email (returned in a group of documents received in response to a November 23, 2009 Freedom of Informa- tion request), Paul Curtis, the principal scientific advisor to the trustees and architect of the deer killing plan, said "Immigration is extremely difficult to measure, and little is published on this topic. The situa- tion in VCH would provide a unique case to actually measure immigration rates if a known number of adult females were tagged, and all other deer were removed. I don't think such a field experiment has ever been conducted previously." This confirms how fundamentally the deer killing program is an "ex- periment," which only emphasizes the obligation of the trustees to include detailed information about the nature and purpose of the activities to be performed under the rubric of"study." These activities are of such a scope to require the disbursement of a substantial portion of the budget, yet no details 10 whatsoever are specified. Further, based on the limited information available, these activities appear to bear no essential relevance to the accomplishment of the goals set forth in the DEIS for the action. The omission of this information is inexplicable, particularly given the level of interest local citizens have demonstrated in this part of the Draft Deer Remediation Plan prior to release of the DEIS. At September 13, 2010 Board of Trustees meeting, Catherine Stein, a VCH resident, asked specifically what the $275,000 listed in the "Draft Plan Cost Analysis" for "Modeling/tracking study" would actually pay for. No explanation for the duties to be performed for this sum of money, or the justifications for the inclusion of such research duties in a tax-payer publicly funded program were offered to Ms. Stein at that time by Mayor Supron or any of the other trustees. At the next meeting of the trustees, on Oc- tober 12, 2010, another VCH resident, Guy Tabacchi, inquired as to what these funds were intended to pay for, and again, Mayor Supron would not answer this question in a public forum. At the next meeting of the Trustees on November 8, 2010, Catherine Stein again raised this issue, and again, was not given an answer. Furthermore, two Freedom of Information requests produced no further details about the basis for this figure. We therefore request that the trustees take the necessary steps to supply the public with the detailed information which has been omitted from the DEIS for unknown reasons and is clearly necessary to understand the nature of the activities associated with the major budget item of"modeling/track- ing study." We further request that that the public then be given sufficient time and the opportunity to comment on this new information prior to the preparation of a final Environment Impact Statement, pursuant to New York State environmental law. Issue #3: Request that data be collected to make a realistic assessment of ecological dynam- ics in the Village in order that a scientific assessment of the impact of the deer population on other species may be developed and tracked over time, and that once this data is collected and analyzed, full consideration be given to alternatives for promoting "biodiversity" that have less negative impact than the proposed deer killing plan In the DEIS, it is claimed that the presence of deer is having a negative effect on "biodiversity" in the Village, to the point that over 400 species are specifically listed in this context, the clearly intended im- plication being that killing most of the deer in the village will have a correspondingly positive effect on these species and hence, enhance the Village's "biodiversity." No Cayuga Heights-specific data is of- fered to support this argument. Further, in the DEIS it is acknowledged that deer are a keystone spe- cies, emphasizing their centrality in the Village's ecology and indicating that their removal will have numerous and complex implications. To assume that this action has no significant impact, or that the impact will only be "positive," is nonsensical. Additionally, as others have pointed out, the use of the term biodiversity in the context of an almost completely developed 2 square mile municipality borders on being absurd, or even disingenuous. This fundamental misuse of basic biological concepts notwithstanding, in reading the DEIS, it is clear that the trustees have failed to consider at all an alternative to the wholesale prevention of species loss with far less extreme negative impacts than an annual backyard mass slaughter of deer. Free- dom of Information Law requests submitted on 8/25/10 and 11/12/10 returned no documentation of: 1)Any efforts the Village has made in the last 5 years to assess the presence of any of the over 400 species of concern listed in the DEIS at any sites slated for development, or 2)Any cancellation or even modification of even one development project for the purpose of protecting even one of the over 400 species of concern listed in the DEIS that are implied, without the presentation of Cayuga Heights specific data, to be threatened or in some way harmed by the presence of deer in the village. I It is well documented that human development of the landscape is exacting a heavy price on, and even devastating, the environment worldwide. Therefore, until a systematic scientific study of the ecology of the Village is conducted over a series of years, it is not even possible to say whether the number of species is increasing or decreasing in the Village, what effect deer may be having on what- ever change is occurring, and why other factors, such as development projects and climate change are not dramatically more responsible for undesirable changes than local deer. In the meantime, in the absence of even the most basic location specific data collection and scientific analysis, it seems clear that regulating development and/or fencing in environmentally sensitive areas would be viable alternative approaches to reducing species loss and to actively fostering species diversity than the proposed plan. Furthermore, such efforts could bring positive results without any of the destructive impacts that come along with implementing a divisive, violent program that results in destroying most of the members of an indigenous species. Issue #4: Request that full consideration be given to alternatives addressing the risk of Lyme disease that have less negative impact than the proposed deer killing plan. In the DEIS, it is stated that decreasing the risk of Lyme disease is one of the objectives for the imple- mentation of a program to kill the majority of the deer who live in the Village. (Cayuga Heights Deer Management Plan DEIS Executive Summary: page 1-6 ). Numerous recent scientific studies have conclusively refuted the idea that killing deer is an effective approach to reducing the incidence of lyme disease. Indeed, neither the Tompkins County Health Department nor the American Lyme Dis- ease Foundation recommend the killing of deer as a strategy for reducing the risk of Lyme disease. Instead, our local health department recommends preventive practices including such things as the use of proper attire when walking in tall grass and developing a greater ability to recognize tick bites to insure prompt treatment. The fact that the Village trustees have been publicly discussing the risk of Lyme disease for over two years now in the context of promoting a deer killing program, and in that time, have not implemented a Village-wide education program about Lyme disease based on our local health department's guidelines, is testimony to how little consideration the trustees have given to this low-cost, yet highly effective alternative to a deer killing program. We hereby request that the trustees take action to redress this deficit and make a serious evaluation of this alternative to the deer killing program that offers true preventive value and that will clearly have negligible negative impacts in comparison to a deer killing program. Issue #5: Request that full consideration be given to alternatives for reducing the rate of deer- vehicle collisions that have less negative impact than the proposed deer killing plan In the DEIS, it is stated that decreasing the rate of deer-car collisions is one of the objectives for the implementation of a program to kill the majority of the deer who live in the Village. (Cayuga Heights Deer Management Plan DEIS Executive Summary:'page 1-2). Roadside wildlife warning reflector technologies are being used all over the world, and studies show them to be effective. According to the traffic engineer of Owego, NY, the "Strieter Lite" system reduced deer-vehicle collisions by nearly 100% in the areas it was installed. During early meetings, this technology was summarily rejected by the Deer Remediation Advisory Committee for "aesthetic" reasons, which seems unjustifiable in comparison to the importance of potentially preventing automobile accidents. Another alternative, the Roadside Animal Detection System, uses sensors to detect large animals approaching a roadway, and sends out a warning signal alerting drivers to reduce their speed. One study found that these systems can reduce collisions up to 82%. Since 2008, the trustees have been informed and regularly reminded of the existence of these options, and yet, the DEIS offers no serious consideration of this 12 low-impact, reasonably priced and highly effective alternative to the annual mass slaughter of the lo- cal deer herd. Local citizens have also frequently suggested at meetings that speed limits be lowered, speed bumps be installed, and that speed limits be more strictly enforced. These viable alternatives are also given no serious attention in the DEIS. We urge the trustees to carefully consider the requests we have made and the information we have brought to light. We believe the evidence and argument against a deer-killing program in Cayuga Heights is overwhelming, and that our entire community will be well-served by the abandonment of this divisive and violent proposal. In contrast, the numerous non-lethal alternatives presented over the last two years by many people in our community offer a wonderful opportunity to bring us all together behind an approach that focuses on reducing deer-human conflict, rather than eliminating deer from our environment. Sincerely, Jenny Stein, 41-year resident of Ithaca �aU'A James LaVeck, 25-year resident of Ithaca Eric Huang, 9-year resident of Ithaca 13