Comment Letter Environmental Impact Statement Essay

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solicited in connection the presence of the white-Tailed deer at Catoctin Park.

Due to the problem of the white-tailed deer hampering forest regeneration at Catoctin Mountain Park, the Park is considering implementing one of four action alternatives. The selected plan will become the final white-tailed deer management plan that will guide further actions for at least the coming 15 years. The proposed action plan runs from the most benign intention of placing certain controls in check to the most malevolent that includes sharp shooting and euthanasia of deer as well as deliberate plans to stem their reproduction ( United States Department of the Interior National Park Service Final white-tailed deer management plan, n.d.). After carefully evaluating the merits and demerits of each of the plans, this correspondent recommends Approach B. As the most feasible, ethical, and pragmatic implementation for reasons mentioned in this petition.

As you write, Catoctin Mountain Park prizes its historical past and significant present as conservationist and tourist site. Amongst its high points is the fact that 46 recreational Demonstration Areas were established in the 1930. Of the 17 remaining parks, Catoctin remains one of them. It also serves as a natural buffer zone protecting the presidential retreat where numerous international political events shave been convened, as well as playing a significant role as watershed to neighboring Monocacy River, Potomac River, and the Chesapeake Bay.

The Problem

Unfortunately, white-tailed deer have been ruining the natural vegetation of Maryland landscape in general and of Catoctin Mountain Park in particular. They have been doing this by destructing and/or negatively impacting each of the following:

Vegetation - by browsing and thereby destroying herbivorous plants and trees, specifically deterring tree growth from attaining the desired condition of a sustainable hardwood forest, and from permitting a mix of native herbaceous plant species to flourish. The deer also threaten endangered and sensitive plant species and their habitats.

Wildlife habitat - the white-tailed deer threaten lower canopy and ground-nesting birds and other wildlife habitat. These have to be protected from their browsing.

Cultural resources -- Browsing, trampling, and seed dispersal ruins vegetation that contributes to the Park's cultural landscape.

Visitor experience -- Deer have negatively impacted visitor's experience of the park by causing accidents and by other adverse activities. ( Chapter 1 Purpose and Need for Action; Chapter 3 Affected Environment; Chapter 4 Environmental Consequences).

Proposed Actions

Catoctin's original deer management plan issued in 1995 issued a finding of 'no significant impact' in regards to its deer populace. The Park has, however, find cause to dramatically alter that decision and, given wide spread destruction caused by deer, to adopt one of 4 plans. These are the following:

Alternative A -- this is the preferred 'no action plan' where deer would be restrained by limited fencing, use of repellents in landscaped area, monitoring, data management and research.

Alternative B -- would introduce the following in addition to plan A: incorporate non-lethal actions to protect forest seedlings, promote forest regeneration, and, in non-lethal ways, gradually reduce deer in the park primarily by intensified use of enclosures and increased use of repellents.

Alternative C - would include the plans of A but supplement that with lethal methods that would include direct reduction of deer herd by sharp shooting and capture and euthanasia where sharp shooting is inappropriate.

Alternative D - would include actions under alternative A combining those with lethal and non-lethal alternatives from B. And C. Added to the lethal plans of C. would be deliberate reproductive control of deer in order to reduce herd numbers ( Chapter 2. Alternatives).


For ethical and pragmatic reasons, it seems to me that Plan B. would be the most feasible. Even though various states, prominently Virginia and New Jersey have adopted sharp shooting methods to reduce their deer population, and even though they have been successful in doing so, for various reasons I think this an unwise step to adopt. Societies such as the World Society for the Protection of Animals (WSPA) and other associations dedicated to protection of animals may cause unwanted publicity to the Park's actions, and this publicity may consequent in marked reduction of tourists and declension in business as well as providing the park with a negative reputation that it may find hard to abandon. Imagine the reaction of tourists to signs indicating that certain areas have been closed off due to deer culling, or to tourists sighting deer burial pits, smelling the burning of their carcasses, seeing carcasses sprawled around, or reading about the doe genocide that is occurring in the park whose beauty and back-to-nature experience these visitors seek. Deer constitute an integral part of this back-to-nature experience. They are more welcome to tourists than the Park imagines. Even though the NPS does record that shootings will occur during winter which is the most lax time of the year, nonetheless an average of 2000 people visit the park during this time (NPS, Chapter 4). This is no insignificant number. It is for all these reasons (and more provided later) that it seems to me that, given failure of plan A, Plan B. would be the next optimal solution (followed by the sterilizing recommendation that I include later).

Alternative C. is a weaker form of Alternative D. but, nonetheless still involves perpetrating morally questionable actions in pursuit of protecting the park and has all the problems mentioned in regards to Plan D.

Alternative A -- which is the park's preferred plan may likely be insufficiently effective, and needs to be bolstered. In this way, it makes sense that Alternative B -- which includes reinforced conditions of protection including research -- remains the preferred approach since it is wise and pragmatic as well as most socially pleasing in its ramifications.

Alternative B. is particularly appealing since deer are important to our existence. They constitute part of the ecosystem in which we reside and as such play a significant role in maintenance of the food web. In fact, many researchers consider deer so important to the food web that killing them is destructive to our situation, This is because they are a keystone species (otherwise known as ' ecosystem engineer') shaping the very communities of which they are a part (Rooney, & Waller, 2003).

Yes, it is true that the white-tailed deer are, in consuming the plants and minor wildlife, negatively impacting plants, population, and herbivorous communities aside from threatening rare vegetation, but to say that they are endangering the continued surveillance of a forested ecosystem may well be an exaggeration, particularly since most studies have detected effect on plant survival to exist only on a minor temporal and spatial scale (Russell, FL et al., 2001). There are no long-term overall effects, and short-term effects can be impeded in their initial stages.

Also important to consider is the fact that, as one correspondent observes (NPS.Gov. Chapter 9 Letters), NPS quoted a larger amount of deer to exist both in Maryland itself and in the Park in particular than actually do exist. Major ecological alternations in the ecosystem have led to variations of deer densities and it is quite likely that past deer density, contrary to the Park's assertion, exceeds that of today.

Lethal removal of deer contradicts the park's founding objective, which was to provide a free place for roaming and protection of wildlife. In fact, the central mission of NPS -- as one correspondent pointed out - is to refrain from interfering in natural processes unless a compelling case can be made that other preventative measures have first been adopted. This naturally wipes out Plans C. And D. from consideration at least until Plans A fortified by B. have been tried and conclusively and objectively showed to have failed.

Voluntary research of similar problems involving white-tailed deer, that have affected other states and parks and the way that these institutions dealt with them, provide me with some further ideas that may be of use to you:

Between the years 2002-2005, Highland Park, Illinois trapped, sterilized, and released its deer in order to reduce a population that was causing an annual high rate of car accidents (Matthews NE et al., 2005). Deer were sterilized through tuba ligation that was a safe method proved to refrain from disrupting their hormones as resulted in other methodologies. The surgical method was not only safe and humane but also resulted in lesser deaths. Computer models revealed that annual sterilization of 32% of the deer population could be a safe and humane way of restricting their density (ibid). This may be a viable option for the Park to consider were Plans A and B. To fail and were they to insist on proceeding with Plans C. And D. Implementation of sterilization as opposed to euthanasia or sharp shooting would leave a certain deer population behind in the community which, although unable to reproduce themselves, would serve as continuity markets in the social framework and existence of the herd.


In conclusion, I recognize that the white-tailed…[continue]

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