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HomeMy WebLinkAboutCayugaDeer section 4.pdf Cayuga Heights Deer Management Plan DEIS:Community Response Stein, La Veck.Huang(p. 37-49)-Page 47 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 8125/10 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 Cayu a Heights Deer Management Plan DEIS,Community Response Stein,LaVeck,Huang(p. 37-49)-Page 48 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 Cayuga Heights Deer Management Plan DEIS.Community Response Stein, La Veck, Huang low-impact, reasonably priced and highly effective alternative to the annual mas �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 Ithaca, NY 14851 James LaVeck, 25-year resident of Ithaca Ithaca, NY 14851 Eric Huang, 9-year resident of Ithaca Ithaca, NY 14851 13 Cayuga Heights Deer Management Plan DEIS.,Community Response Sherene Baugher, PhD(p. 50-51)-Page 50 Ithaca, New York 14850 December 16, 2010 Cayuga Heights Trustees 836 Hanshaw Rd. Ithaca, NY 14850. Dear Mayor and Trustees of Cayuga Heights, I am writing this letter regarding the Draft EIS on the deer-killing plan. As a professor from Cornell University who has to apply science and accepted scientific procedures in my analysis I am deeply concerned that the Draft EIS lacks scientific rigor and it seriously raises the question of the validity of any of its conclusions. The DEIS bases its belief on what the community thinks regarding "the deer problem" on a survey done in the 1990s (no specific date is given and nor who did the survey) and the survey was only of property owners. The survey is minimally at least 10 years and perhaps 15 or more years out of data and it also excludes all of the renters in Cayuga Heights who would be impacted by a deer killing plan socially, psychologically, and economically (in terms of the increase in taxes being passed along to them in increases in their rent). The deer count was not a systematic deer count accepted in scientific studies (no scientific study is provided) but it appears to be a personal estimate of the deer population by Dr. Curtis of Cornell University instead of a scientific study. Since the proposal of numbers of deer to kill is not based on hardcore scientific data in a scientific study it does raise the question of how valid is the proposal of numbers of deer to kill. The DEIS study discusses the problems of lyme disease in Maine and then suggests that this is a serious problem for the citizens of Cayuga Heights. However, no data is given on how many residents of Cayuga Heights have contacted lyme disease in Cayuga Heights and there is no study of lyme disease in Cayuga Heights to scientifically demonstrate that there is growing problem over the last few years or even if there is a problem at all. There is simply a veiled threat that if the deer-killing program does not go forward lyme disease will become a serious health issue for the residents. This is not science, this is simply opinion based on emotion not facts. An EIS should deal in facts. The study provides minimal discussion of the other alternatives to the deer-killing program. There are scientific studies of alternatives to deer-killing that have Cayuga Heights Deer Management Plan DEIS.Community Response Sherene Baugher, PhD(p.50-51)-Page 51 been discussed in public hearings but those studies are NOT included DEIS. There are studies showing that deer-killing has not worked in other communities that have been discussed in public hearings but those studies are NOT included DEIS. No discussion of the effectiveness of fencing is presented in the EIS although it has been discussed at length in public hearings. This draft EIS is seriously flawed and the Board of Trustees needs to address these flaws before reaching informed conclusions. There are numerous adverse impacts to a deer-killing plan and the Trustees of Cayuga Heights should not move forward to taking such a step based on a seriously flawed document. Sincerely, Sherene Baugher, Ph. D. Cayuga Heights Deer Management Plan DENS:Community Response Karen Kaufmann(p. 52-58)-Page 52 My name is Karen Kaufmann and I have lived at , in the Village of Cayuga Heights, for 20 years. I cannot attend the public hearing on the Deer Remediation DEIS scheduled for December 6, 2010. I submit this statement instead. 1 am apalled and deeply ashamed that my neighbors in the Village are willing to move ahead with a program of mass slaughter on the flimsy collection of inapt suppositions and unquantified speculations set forth in the DEIS. I would urge the Board to demand additional, local, data collection and quantification before approving this document or proceeding with the program. For instance, the DEIS begins its analysis with a general overview of studies purporting to show the impact of whitetail deer populations in natural-- specifically, forest-- ecosystem regeneration and environmental diversity, with only a small caveat that the Village is not a forest. Yet it goes on to use deer-density criteria drawn from such studies to support the Village's assessment of the optimal or acceptable deer density in the Village. Clearly, if ecosystem regeneration or environmental diversity is the Village's goal, as the DEIS and the Village's supporting EAF both suggest, culling ought to be the penalty for any ecosystem- or diversity- destructive activity-- for instance, when 1 clear brush from the back portion of my lot, or when the few remaining undeveloped plots in the Village are put up for development, or when we spray pesticides on our unnatural lawns. In addition, on the issue of density, the DEIS is upfront in pointing out that a deer population enumeration is difficult if not impossible to obtain. Nonetheless, it goes on to premise the need for and impacts of mass culling on repeated references to excess population density, based on projection from a 4-year-old "count" based on population modelling. The projection may or may not be accurate, especially for the 2010 season, when folks in the Village have repeatedly observed that there seemed to be fewer fawns and fewer multiples than in previous years. The bottom line is, however, that the impact of the culling proposal on the deer and on the rest of our Cayuga Heights Deer Management Plan DENS.Community Response Karen Kaufmann(p. 52-58)-Page 53 Village environment cannot be accurately gauged without at least some current population count or data-based modelling, if only to know how many deer must be killed, how much shooting must be done, how many days or nights of gunshot and neighborhood police stake-outs we must endure, how much waste must be disposed of, how many truckloads of personnel, equipment, and waste must traverse Village streets and for how many years in order to achieve ephemeral "stability" of the deer population. Beyond that, if ecosystem preservation or environmental diversity is the Village's goal, isn't it ironic to find that, for the three identified "unique natural areas"remaining in the Village, no enumeration of species, no quantification or any other measure of deer damage, and no analysis of the impact of culling, has been undertaken or assigned? We are talking about mass slaughter of close to 200 deer, at a cost of$1 million over a period of five years, purportedly to maintain environmental diversity, with no data to even suggest that such diversity actually exists, is threatened, or will be impacted here in our well-manicured Village or its residual unique natural areas. A similar lack of data or data analysis is evident in discussions of Lyme disease, deer-vehicle accidents, and the alleged problem of"untreated waste." Notably, the Board, in its EAF, pointed to information from the American Lyme Disease Foundation acknowledging that Lyme is actually percolated by mice, although transmitted long distance by deer, and that effective Lyme control would entail a reduction in mouse population and/or the use of tick pesticides to reduce Lyme incidence; while the DEIS, touting the prospect of Lyme control, relies on a precis of studies actually concluding that Lyme control through deer culling remains inconclusive with regard to human disease, and/or demonstrating that such control is most compelling where captive deer populations are involved. There are no statistics offered for Lyme disease incidence in the Village; and even Tompkins County statistical reports, while warning that Lyme can be contracted in the County, Continue to suggest that the reported incidence does not necessarily Cayuga Heights Deer Management Plan DENS.Community Response Karen Kaufmann(p. 52-58)-Page 54 reflect locally-acquired tick bites. It is sheer speculation to suggest that killing 200 deer will prevent Lyme disease locally, particularly as the Village boundaries are permeable and deer abound in the surrounding areas. Likewise with automobile accidents: while the DEIS does cite to statistics for 2003-2008, it does not analyze them by year, or by location, or by reporting protocols, to identify any upward trending or any correlation with traffic, speed, or terrain. In addition, the DEIS use of correlate statistics for the Village reporting category of deer-related "incidents" is suspect, as the DEIS misinterprets the category, describing such "incidents" as instances where, although no vehicle is present, the police must shoot an injured deer; whereas Chief Boyce clearly explained, in reports to the Board during the Board's preliminary environmental assessment, that "incidents" included all deer-related complaints, not necessarily vehicle-related nor necessarily involving the shooting of an animal. Can an assessment of the beneficial impact of the culling plan for drivers really rest on such a poverty or misinterpretation of data or analysis? And on the alleged problem of untreated waste entering the local watershed, there is no quantification of current deer-related waste production, nor any environmental analysis of the contribution of deer scat to water quality relative to other waste, nor, apparently, any concern about the infusion of lime-treated deer guts into the waste stream in the remote location where the waste will be trucked, or about the environmental costs of trucking waste away from the bait sites and out of the Village. Anyway, if deer scat poses a waste-stream threat sufficient to justify mass slaughter, as the DEIS implies, then let's put a comparable death warrant out for commercial pesticide operations, for rabbits and crow, geese and coyote, and other wild waste producers, for those dog owners whose canine feces rot in our yards and along our sidewalks. Notably, although the DEIS purports to address alternatives to the Board's culling plan, it does not discuss any non-invasive alternative besides the "do-nothing" option. Yet for concerns with Cayuga Heights Deer Management Plan DENS:Community Response Karen Kaufmann(p. 52-58)-Page 55 collisions, ticks, and vegetation, there are clear non-lethal non-invasive options that the Village could implement at minimal cost— from speed reduction/enforcement and reflective lightposts to a revised fencing ordinance that would address the concerns of gardeners and homeowners much more efficiently and at lower cost to the taxpayers than a large-scale population control program. Likewise, the DEIS analysis of a sterilization-only alternative quickly writes off that option as too protracted—with a three to five year trajectory-- to meet Village stabilization goals, ignoring completely the evidence that the Village's previous sterilization program saw a marked decline in population in the two or three years it was in operation, that plans for culling have given rise to nearly three years of conflict and controversy in the current go-round alone, that the current plan's own projections call for one to two years of sterilization and five years of culling and maintenance operations thereafter, and that in other communities a commitment to culling, once begun, is unending. Unlike the non-invasive options for highway safety and property-protection, or even the non- lethal option of sterilization for deer population control, the Village's culling plan will bring long-term and pervasive change to our community— from the five-plus years of shooting that it is projected to entail (as noted above, other communities have found that their initial short-term projections continue to drag on), in backyards and neighborhoods that will be off-limits to residents, neighbors and passers-by for the duration of operations, at times and places that will be unannounced (despite the DEIS promise of"constant communication between [sic] community members, municipal officials and the culling agent" during shooting operations), with the sounds of gunshot, struggle, and painful death becoming a feature of our daily life for unspecified periods each shooting season. I will most certainly not be allowing such operations to occur within 500 feet of my home. Moreover, as an all-weather, all-hours walker along Village streets, I am concerned about the Cayuga Heights Deer Management Plan DEIS:Community Response Karen Kaufmann(p. 52-56)-Page 56 plan's clear—but scantily addressed— impact on pedestrian and roadway safety and peace of mind, and on the pattern of daily life in the Village, particularly if shooting sites are unannounced. 1 am also concerned about the polarization of our community around this issue, particularly as the Board continues to blame "outside agitators" for opposition to the culling plan and gives scant heed to the number or deep-seated concerns of resident opponents. 1 am concerned about the message we send our children in the Village in looking first to violent population-control measures to address issues that revolve largely around our own convenience or desires; and about the image and public perception of our community, as we opt to spend millions on violent deer control while the county, the state, and the national economy are in a phase of deep cutback and human suffering. I implore the Board to look as deeply at these impacts as at the speculative prospect of an easy life without deer offered by the DEIS, and govern yourself accordingly. Thank you. Cayuga Heights Deer Management Plan DENS:Community Response Karen Kaufmann(p. 52-58)-Page 57 Ithaca, New York 14850 December 14, 2010 To the Members of the Board of Trustees Village of Cayuga Heights Re: Deer Management Plan, DEIS Friends: 1 offer the following comments as a supplement to the statement I previously submitted in response to the Village's Deer Management DEIS. My previous statement raised concerns about the inapt presumptions and sheer speculation that pervade the DEIS. The present comments raise more pointed questions about the impact of the deer management plan on the character of our community and the inadequacy of the DEIS assessment of such impact. My husband and I moved our family to Cayuga Heights in 1990. We had spent the previous decade living in the Town of Ithaca,just outside the City of Ithaca, on Ithaca's West Hill. We chose to move to Cayuga Heights for its unique residential qualities: its extensive network of walkable sidewalks, the 30-mph Village speed limit, proximity to the elementary school and a safe environment for children and pets to roam in, a friendly and competent police force and other Village services, and, not least, restrictions on firearms that— unlike our West Hill experience— allowed us to feel safe outdoors in all seasons. We most decidedly did not move here to live next to, or within hailing distance of, a military encampment or a slaughterhouse. And yet that is what the Board's deer management plan is imposing on us, without any acknowledgement—in the DEIS or elsewhere— of the change in the character of our residential community that such usage entails. Rather, the DEIS concludes, blithely, that the primary impact of the deer management proposal on quality of life in the Village will be a transient increase in the night-time ambient noise level due to gunshot. That is simply not a full or fair assessment of either the original bait-and-shoot proposal or the DEC's suggestion for net-and-bolt slaughter. If the Village moves ahead with its initial bait-and-shoot proposal, the experience of other communities suggests that the six to ten bait-and-shoot sites will take on the qualities of a military operation, particularly if the assurances of safety oversight promised by the Village and touted in the DEIS are fully implemented. There will, at the least, have to be a pre-shooting site search (in some communities, by helicopter flyover, in others by police foot search), a police cordon, night lights, an amassment of the vehicles from which shots are to be fired and into which the field-treated carcasses and other waste will be loaded. The experience of other communities also suggests that the process will not be quick or transient, but will drag on for weeks. Where is the DEIS assessment of this neighborhood impact, or of the costs of implementing the safety assurances and environmental abatement of bait-and-shoot killing— in increased police and public works manpower costs, for example, or in the environmental costs of Cayuga Heights Deer Management Plan DEIS.Community Response Karen Kaufmann(p.52-58)-Page 58 lighting, vehicular use, yard damage, and waste management, or in the possibility of liability should Village supervision of operations result in public injury? Even worse, if the Village chooses the net-and-bolt option, the DEC's own description—echoed in public comments by Mayor Supron— is that this process uses the techology of the slaughterhouse to put the animals to death. I most certainly did not choose to live next to, or in hailing distance of, a slaughterhouse—a prospect that I find all the more chilling if, as has been suggested, the net-and-bolt option does not require 500-foot waivers or the minimal advance notice that a waiver entails. The DEIS assessment of net-and-bolt is minimal; indeed, it recognizes that the costs—whether financial or environmental is not specified— of such a program are unknown. Before any such process turns my neighbor's yard, or my neighborhood, into a slaughterhouse, at the least some assessment of the horrifying community impact of the process must be done, and some more concerted attention paid to alternatives and mitigation. Indeed, in most communities slaughterhouses and firing ranges fall into special zoning categories reserved for noxious or toxic industries. They are most certainly NOT permissible residential uses, particularly in the Village, where even non-noxious fences and signs are highly controlled. I am hard-pressed to see that the DEIS, or the Board, has adequately addressed the noxious qualities of either the bait-and-shoot or the net-and-bolt option, or their deleterious impact on the character and quality of life in theVillage. I know 1 am not alone in finding these options inconsistent with the residential character of the community 1 chose to live in, or in finding abhorrent and unacceptable the prospect of living in a neighborhood where shooting or bolting is conducted, especially without adequate consideration and/or trial of alternatives. I once again urge the Board to make a fair and data-driven assessment, not only of the projected impacts of a deer management plan, but of the specific problems and complaints that have driven the search for management options, and of the non-lethal approaches that might more effectively— in cost, in community buy-in, and in long-term sustainability-- address these problems. — Karen Kaufmann, VCH Cayuga Heights Deer Management Plan DENS:Community Response Steve Shiffrin(p. 59-63)-Page 59 Mmuwdm To: Mayor and Village Board of Cayuga Heights From: Steven H. Shiffrin, Village Resident Date: 12/13/10 Re: Deer Management Plan Draft Environmental Impact Report I appreciate the opportunity to submit comments on the Draft Environmental Impact Statement. Despite our differences, I am grateful for your work, and 1 recognize that honest and intelligent people can disagree about the deer issues facing the Village. Nonetheless, I think the Statement has some serious weaknesses. I will focus on two: I do not think the Statement shows that the recommended plan can obtain the needed political support over a five year period and I do not believe that it offers a serious consideration of alternatives to its plan for killing deer. The Lack of Political Feasibility The Statement concedes that the plan will need political support over a five year period. It presumes that the plan has current support because the Board was elected against opposition on the deer issue. This presumption is misplaced. The plan is not practical. Although people vote for many reasons, it does seem likely that the deer issue decided the election. The election was between those who wanted to leave deer alone and those who were prepared to kill them. The issue of a compromise involving contraception or sterilization as the exclusive method of reducing the deer population was not presented as an election choice. It seems to me that the election shows that a strong majority of the village population wants to do something to reduce the herd. It does not show that the population was in favor of killing, or killing combined with sterilization, as opposed to sterilization and fencing. Indeed, the Deer Committee endorsed the Cornell study in the late 1990's that 80% of villagers wanted to reduce the herd, but those who favored killing the deer were in a minority that did not exceed 30%. (Appendix D) The Statement has no data to support its view that the majority favor killing of the deer(let alone killing deer with bolts). Of course, the Board has 1 Cayuga Heights Deer Management Plan DENS:Community Response Steve Shif/rin(p. 59-63)-Page 60 December 17, 2010 the power to proceed without a majority in support of its actions, but without popular support over a five year period, the plan will fail. Whatever support the plan has now, there is reason to believe that support for it will decline over the next five years. It appears that the primary support for the plan in terms of numbers comes from those who are concerned about their gardens. This was the finding of the Deer Committee and the impetus for its establishment. (See Appendix D). And the Statement is not to the contrary. It does not point to lyme cases in the Village and it does not show that traffic accidents have increased in the Village. As the tentative budget for the Plan discloses, the cost for the proposal amounts to a 3.45% increase in the Village budget. It is reasonable to assume that the Village budget will need to be further increased for other reasons (do Village budgets ever go down'?), If there is one thing we know about the American people (I doubt the villagers are an exception), they want many things, but they do not want to pay for them. When taxes go up, villagers will grumble and those who wanted to protect their gardens on the cheap may reconsider in a difficult economy. Under these circumstances, villagers will also examine the budget with some care. I expect future political candidates will have a field day in attacking the Board on grounds of fiscal irresponsibility. The plan calls for the expenditure of$150,000 each year for five years ($750,000) and an undisclosed amount thereafter. It has a goal of reaching a herd of 30 deer for 1.8 square miles (even though its figures show that other governments have sought to achieve 25 per square mile or what would be 45 for our community). The figure of 30 deer for 1.8 square miles seems to be completely arbitrary. It has no scientific basis, and the Statement does not even attempt to show that it has community support. But, taking the Statement's figures, the Board would sterilize 30 deer at a cost of$1,100 per deer(see Executive Summary) at a total cost of$33,000 and would kill the 170 other deer it estimates to be in the herd at a cost of$500 per deer(see Executive Summary) at a total cost of$85,000. This totals $1 18,000. Even assuming another 20 deer come into the community to be killed ($10,000), the total figure for killing and sterilization, does not exceed $128,000. This leaves an expenditure of$622,000 to be explained. I have seen a document from the Village that budgets $30,000 a year for two years for a deer management professional (I assume this is for the sterilization period and that the Police Chief would protect public safety when the killings begin). This still leaves $562,000 to be explained. I do not think an expenditure of this character is politically defensible, and no evidence in the Statement suggests otherwise. If the Board plans to spend $562,000 on studies and unspecified contingencies, I would think any political consultant would forecast that it should plan to lose a lot of political support. 2 Cayuga Heights Deer Management Plan DENS:Community Response Stave Shi/frin(p.59-63)-Page 61 December 17, 2010 Finally, when the killings begin, there are risks of deteriorating support. Killing in the abstract is one thing; when people hear gruesome stories, many will lose their stomach for the enterprise. This would be especially true if the Board adopted a net and bolt plan. A study by Hastings-on Hudson concluded that no community has been able to sustain a net and bolt program and that government has opted for a contraception program. http://hastingsgov.org/Pages/HastingsNY Issues/New%20Folder/Deer%20Presentation.pdf The Board recognizes that its proposed plan cannot work without support for five years, yet there is little evidence in the Statement that gives any grounds for believing that any present support will be stable. Communities have started deer plans only to lose political traction. To suppose that the Village will be politically stable around this plan without supporting evidence is to engage in a kind of riverboat gamble: a gamble with the tax money of the Village, a gamble that risks further community polarization and deterioration. There are better alternatives. Alternatives New York law requires that an environmental impact statement "must analyze the significant adverse impacts and evaluate all reasonable alternatives" [6 NYCRR 617.9(b)(1)]. I maintain that the Statement substitutes conclusory assertions for evaluations. It does not meet the legal requirement. The Statement dismisses contraception and/or sterilization as the exclusive method of reducing the herd, but it lacks evidence to do so. It should be observed that sterilization was tried in the Village before and the Statement recognizes that it reduced the herd. Surgical sterilization was abandoned by the Village when Cornell was no longer willing to make its facilities available. The Village Board at the time shifted to darts and serum as a method of contraception, but the particular serum was ineffective. Apparently, the Board has relied on Paul Curtis for the proposition that such methods are always ineffective. But the views of Curtis are contested in the scientific literature and in local communities which have examined the evidence. To hear Curtis is, of course, responsible. But to rely on him without a serious consideration of the contesting evidence is excessively provincial (the local expert is not always right) and is inadequate legal support. For example, Jay F. Kirkpatrick, a Cornell Ph.D. in reproductive physiology from the College of Veterinary Medicine at Cornell University in 1971, is a nationally recognized expert in this field. He has spent 38 years carrying out research on fertility control for wild horses and other wildlife 3 The Deer Remediation document in Appendix E states that its conclusions are drawn largely from a paper by Paul Curtis.As I suggest below,following a local expert who has taken one side in a national controversy without examining or discussing the evidence on the other side is inadequate consideration of alternatives in an Environmental Impact Statement. 3 Cayuga Heights Deer Management Plan DENS:Community Response Steve Shiffrin(p. 59-63)-Page 62 December 17, 2010 (including deer), for the purpose of developing non-lethal and humane methods of controlling wildlife populations He is currently the Director of the Science and Conservation Center at ZooMontana, in Billings, and has consulted with numerous communities including the city of Pittsburgh. His conclusion is that contraception with darts and vaccine works. See huh: i��wti zlxunontana.orgisci�n�e-and-conscrvtttion-center;'. To rely on Curtis without considering the arguments of Kirkpatrick in an independent way is indefensible. Similarly, the failure to take account of the attention paid to the issue by Hastings-on-Hudson which has opted in favor of a contraception plan (at a cost they estimate at $400 per deer) for a deer situation far more serious than in Cayuga Heights is further support for the conclusion that the Statement does not discuss the contraceptive issue in the detail it would deserve if it were adequately considering alternatives. The Deer Remediation Statement (Appendix E) does mention that surgical sterilization could take place in a mobile lab that can be shared with other communities (Cornell facilities are not necessary), and the proposed plan does call for some sterilization which constitutes a recognition that sterilization is feasible. The Statement objects to sterilization as an exclusive remedy largely on the ground that it is too expensive. The support for this appears to be that it costs $I,100 to sterilize and $500 to kill a deer. But this depends on the number of does that need to be sterilized (the Statement has no evidence concerning the number of does in the Village) and the Deer Committee concluded that only 70% of the does needed to be sterilized. Even more important, as the Deer Remediation Report observed, the cost figures assume the absence of a volunteer graduate student or volunteer veterinarian (which the Deer Remediation committee recognizes would dramatically reduce costs), and the cost figures do not consider the possibility of private grants. Moreover, the Statement does not take into account the transient character of male deer. Male deer may come in and out of the community inflating the numbers that the Board would kill. Indeed, there is no showing that a killing plan can work in a small area surrounded by a large and mobile population of deer. In truth, the Board does not know if sterilization is more expensive. The Board properly observes that killing deer is faster than relying on sterilization. It suggests without evidence that herd reduction with sterilization would not take place for five to six years, and its killing plan is apparently scheduled to begin in the third year. The Statement does not specify the difference this time differential will make in terms of the environment. Finally, the Board may believe that the 60% reduction of the herd that occurred on Fire Island and the 50% reduction of the herd anticipated by Hastings-on-Hudson is inadequate to 4 Cayuga Heights Deer Management Plan DEIS.Community Response Steve Shiffrin(p.59-63)-Page 63 December 17, 2010 meet the 30 deer goal set by the Village board. But, as 1 suggested earlier, that goal has been supported by arbitrary fiat in reckless disregard of the needs of an Environment Impact Statement. The Statement needs to show that it needs to reduce the herd to that number with appropriate argument that reduction to that number is necessary to avoid environmental impacts that need to be remedied with a solution that is practical (I have argued that it is politically impractical). It needs to make that showing in face of the fact that the deer herd has been at levels tar above 30 without arousing controversy. Only when the herd has risen to a level five to six times the targeted goal has significant controversy been triggered. The Statement does not come close to making its case in support of the 30 deer goal. In the end, the Board does not seriously evaluate the alternatives of contraception and/or sterilization, and it underestimates this: Unlike killing, contraception or sterilization will have widespread support. It is a plan that can be sustained without intense opposition over a significant period of time. 1 will conclude with some remarks about fencing. I am pleased that the Statement endorses at least a temporary change in the fencing ordinance. If vegetation is protected, deer will go elsewhere. If it is not, deer will be attracted to the area. The Report, however, does not seriously consider the combination of contraception or sterilization and relaxation of the fencing ordinance as a suitable alternative to a killing program. It needs to do so both as a matter of democratic process, wise policy and legal obligation. 5 Cayuga Heights Deer Management Plan DEIS:Community Response Lowell Gamer(p. 64-76)-Page 64 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://parkplanning.nps.gov/showFile.cfm?projectiD=14330&docType=public&MI METype=application%252Fpdf&filename=ROCR%2DDeer%2DDEIS%2DJuly%5 F2009smei62Epdf&clientFilename=ROC R%2D Dee r%2DDEIS%2DJuly%5F2009s ni%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. 2 Cayuga Heights Deer Management Plan DEIS:Community Response Lowell Garner(p. 64- 76)-Page 65 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 el 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. 20011. 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). P91-1 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. 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? 3