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Tufts UllageofCayugaHeights
CUMMINGS SCHOOL OF
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Center for Animals and Public Policy
15 December 2010
Village of Cayuga Heights Trustees
836 Hanshaw Road
Ithaca,NY 14850
Re: Draft Deer Management Environmental Impact Statement
Dear Trustees:
I am a scientist with 20 years' experience dealing with urban deer issues and carrying out
research into non-lethal methods of suburban deer population control. I have several concerns
and comments regarding the information that the Trustees are using to make decisions about a
deer management plan for the Village.
In building a case for taking action, the DEIS makes clear that it is the impacts of the deer, rather
than their numbers, that should shape management actions. However, the objectives of the
proposed management effort are expressed only in terms of deer numbers. No targets are set for
reductions in deer-vehicle collisions, reductions in impacts on ornamental plantings, reduction in
Lyme disease rates, or restoration of biodiversity. Indeed,because the Village appears to have
no information at all on deer impacts on ornamental plantings or on biodiversity that are specific
to the Village itself(or even plant inventories within the Village's small natural areas), such
targets are currently impossible to set. Likewise, although the DEIS waves the Lyme disease
flag, it presents no site-specific data related to Lyme disease incidence or risk, and consequently
concedes any prospect for measuring reduction in disease risk associated with the proposed deer
management action.
In my view, accurate deer population numbers are important for the development of management
plans mostly because they define the scope of deer population management. Because there has
been no population assessment for four years,there remains much uncertainty about the number
of deer present, and hence about the outcome of any deer reduction effort. Extrapolation of
wildlife population growth rates into the future is purely speculative, and the further into the
future one extrapolates, the more speculative it is. In Cayuga Heights, where deer population
estimates apparently were stable between 2002 and 2006, there is certainly no sound basis to
postulate a 10% increase over the four years that followed.
From a population management perspective, the DEIS commits a serious oversight in completely
omitting any reference to less invasive methods of controlling fertility in deer. There are two
zoo Westboro Road,North Grafton,MA 01536
TEE:508.839.7991 1 FAx:5o8.8393337
injectable immunocontraceptive vaccines that have been shown to be effective in deer: the
porcine zona pellucida (PZP) vaccine, which I and my collaborators have been working on for
more than 20 years, and GonaCon®, an EPA-registered vaccine that was developed by the
USDA's National Wildlife Research Center. Safety, effectiveness, and population impacts in
suburban deer have been extensively documented for PZP in particular, and recent technological
advances have eliminated the need for annual retreatments (see especially Turner et al.,
"Controlled-release components of PZP contraceptive vaccine extend duration of infertility
Wildlife Research 35:555-562 (2008); Rutberg and Naugle, "Population-level effects of
immunocontraception in white-tailed deer," Wildlife Research 35:494-501 (2008): and Rutberg
and Naugle, "Deer-vehicle collision trends at a suburban immunocontraception site," Human-
Wildlife Conflicts 2:60-67 (2008)). There may ultimately be reasons for not choosing to employ
either of these vaccines, but both deserve serious consideration in a legitimate EIS.
Finally, as a trained ecologist who values wildlife as wildlife, I find myself extremely disturbed
by the proposal to capture and sterilize a subpopulation of wild deer and exterminate the rest.
With this management model, the Village of Cayuga Heights aspires to reduce its wild deer
population to a state of semi-domestication. I do not see much of a future for the coexistence of
people and wildlife if even as progressive a community as Cayuga Heights cannot tolerate
wildlife within its boundaries.
I strongly recommend that the Trustees take a harder look at the proposed management plan,
better define their objectives to meet the community's legitimate concerns with deer, and further
consider less invasive means for managing the Village's conflict with deer.
Sincerely,,,
Allen T. Rutberg, Ph.
Assistant Director
Center for Animals and Public Policy
Cummings School of Veterinary Medicine at Tufts University
508-887-4769
allen.rutberg_(i ,tufts.edu