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HomeMy WebLinkAboutSchmitz, O DEIS.pdf YALE UNIVERSITY School of Forestry & Environmental Studies 14 December 2010 Greeley Lab 370 Prospect Street Board of Trustees New Haven, CT 06511 Cayuga Heights NY oswald.schmitz@yale.edu Dear Trustees, I am,herewith,commenting on the plan to control white-tailed deer within the town limits of the Village of Cayuga Heights. In providing this comment, 1 wish to affirm that I am not being paid by anyone for this service. I am providing feedback in my capacity as an ecologist who has studied white-tailed deer for my PhD dissertation and subsequent research. I have published 6 peer-reviewed papers and book chapters dealing with white-tailed deer ecology and population management. I have looked at all of the documents provided at the website for the draft environmental impact statement(DEIS) http://www.tiiiiiiiillerassociates.COIII/pLtblici-evio k/cavu"ahei fitter, . I am working under the understanding that this is the official document for which comment is request. Below I identify specific informational content in the documents and offer subsequent comment. In the document 2.0 DESCRIPTION OF THE PROPOSED ACTION the proposed deer population control effort in the Village of Cayuga Heights(VCH)is based on the following premises. (1)Many studies in the past 20-25 years suggest that high deer densities affect plant species composition,biodiversity and forest regeneration(pages 2-2,2-3). (2)A substantial deer density can significantly influence wildlife habitat and deer foraging can compromise the ability of an ecosystem to recover, leading to alteration of forest composition and structure(page 2-3).(3)Deer populations above 10 deer per square mile are undesirable if the management goal is to achieve maximum biodiversity(page 2-3). (4)To minimize losses of animal and plant diversity, the management target should be 30 deer or fewer within VCH,or a density of 15 deer per square mile or fewer(Page 2-4). Comment. Re: (1)The document is correct in stating that research over the past 20-25 years has examined how deer can affect species composition,biodiversity and forest regeneration. However,many of these studies are in a single location and could thus be conflated by human land use type and land-use history so that deer cannot be concluded to be a leading factor determining the impact in any one of these studies(see Rutherford and Schmitz 2010,Journal of Wildlife Management 76:1257-1263). Indeed,such conflation of land use on deer populations has been alluded to in 2.3 Project Background... which claims that agricultural practices and forest management has improved and expanded deer habitat and suburbanization of landscapes has created edge habitats preferred by deer(page 2-2). Re: (2)It is correct that high deer densities can significantly influence habitat and forest composition and structure. However,our research(Rutherford and Schmitz 2010),conducted in a similar landscape as VCH,and includes several replicated town sites,again shows that these damage levels are unrelated to deer density per se across a wide range of deer densities. This means that lowering deer densities will not by itself lessen deer impacts on habitat and vegetation. Furthermore,the DEIS never provides criteria for quantifying and assessing damage levels that are acceptable or unacceptable. Hence,there are no a priori criteria to judge success of management aimed at lessening"damage". Re: (3&4)The document is correct that deer densities above 10-15 per square mile can be quite damaging in some areas. But,again,there is wide variation in damage levels,meaning that 10-15 is not a damage threshold,as implied by the document. The document identifies several management goals including(5)VCH should adopt a cultural carrying capacity goal of 15 deer per square mile(page 2-7). (6)VCH should begin a Phased Options Approach(POA)beginning with sterilization of 20-60 does and subsequent culling of unsterilized does(Page 2-7). (7)POA must be implemented in each of the first 5 years of the management program(Page 2-8)and may require continuous implementation in perpetuity(Page 2-9). Comment Re: (5) 1 see no evidence that this population size goal is attainable for 2 reasons. First,the document itself states that deer population [sizes]are difficult to ascertain accurately due to daily and seasonal movements(page 2-4). Thus,there is no evidence provided that accurate estimates of deer will be obtainable to judge the success of the management. Second,because of the acknowledged daily and seasonal movements, the deer population in VCH may not be closed— meaning deer may not be confined within the town boundaries,but may enter and leave VCH. There is further evidence to suggest that VCH does not have a closed population. The current reported deer population sizes(Letter to VCH Trustees from Paul Curtis Dated 12/9/2009—Appendix A)indicates that the deer population size(presumably within VCH boundaries—the exact area of the population estimate is not specified)is very high by deer population standards. However,the population was only sampled in the spring(according to the letter)so the seasonal movement of deer remains unclear. One might expect that under such high abundances,that deer birth rates would slow because of competition for food(called density-dependent feedback). The claim that the deer population is still growing prodigiously(according to the letter)means there is incomplete understanding about the population dynamics on this landscape. One possibility is that deer are moving seasonally into and out of the VCH from the surrounding landscape, are highly abundant seasonally,but are not resident within the VCH. The fact that this alternative cannot be ruled out has implications for(6)and(7). Re: (6)Sterilization, if it works at all,will only work for a closed population. The fact that the DEIS has not provided evidence that the VCH deer population is a closed population means that sterilization,and hence a POA as defined in the document could be altogether untenable. Furthermore,if the population is open,then it will be difficult to reach a target "stable"population size of 15 deer per square mile,even within a single culling period. Because culled deer could be rapidly replaced by deer from the landscape surrounding VCH,there is a likelihood that even a 5 year time horizon will be insufficient to reach a target population size. It may never be reached with an open population and culling efforts focused only on a small part of the greater landscape. Re: (7)The document is correct in suspecting that the PDA will need to be implemented in perpetuity,especially if the VCH deer population is not a closed population. In summary,there is insufficient evidence provided in the documentation to show that the management effort will achieve its stated objective deer population size of 15 per square mile within VCH. Evidence to support the assertion that a deer population size reduction will lessen impacts on ecosystems(habitat and vegetation)within VCH is also insufficient. Furthermore,the DEIS needs to consider the conflating effects of human land use as a driver of deer movements and population growth on this landscape. That is,deer populations may be the consequence of human impacts on the landscape rather than a cause of impacts to humans. Sincerely, 14 Oswald J. Schmitz, PhD Oastler Professor of Population&Community Ecology