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December 19, 2006
Superintendent
Catoctin Mountain Park
6602 Foxville Road
Thurmont, MD 21788
Subject: Draft White-Tailed Deer Management Plan/Environmental Impact Statement
Dear Superintendent:
The National Rifle Association appreciates the opportunity to comment on the Draft White-Tailed Deer Management Plan/Environmental Impact Statement (Plan/EIS) for Catoctin Mountain Park that evaluates four alternatives for managing the population of white-tailed deer in the Park.
Our comments focus on Alternative C (the Preferred Alternative) that calls for qualified federal employees or contractors to reduce the deer population through sharpshooting and capture and euthanasia, where appropriate. We agree that sharpshooting has a greater chance of success than does increasing non lethal methods (fencing, use of repellants, and reproductive control of does) in meeting the Park’s long-term objectives of forest regeneration and protecting, conserving and restoring native species and cultural resources. However, the NRA disagrees with the premise that only federal employees and contractors are qualified to carry out a culling operation.
Under the section of the Plan/EIS entitled "Alternatives Considered But Rejected," a managed public hunt is listed as one of the alternatives considered and rejected. What was not considered was the use of licensed hunters to reduce the deer population in the same manner as the Park would use federal employees or contractors.
Using licensed hunters would not contravene 36 CFR 2.2 nor the National Park Service’s Management Policies of 2001 that state that public hunting is allowed in national park areas only where specifically mandated by Federal statutory law. Secondly, using licensed hunters would be in compliance with authority granted to the Secretary of the Interior to destroy plants or animals for the purposes of preventing detriment to park resources. The purpose of reducing the deer population in the Park is not to provide for a recreational benefit, nor is it to conduct the culling operation as a hunt. The use or presence of hunters does not make the situation a hunt. A hunt is defined by the rules of "fair chase" as proscribed by the state fish and wildlife agency which has jurisdiction over the taking of resident wildlife.
The Plan/EIS states that a managed hunt has not been shown to be more cost effective or efficient than other direct reduction methods such as sharpshooting by agency personnel. It supports that statement by referencing data from several studies suggesting that there is a "minimal to no cost savings by using citizen hunters." There are no known studies on the cost of using citizen hunters as sharpshooters in a culling operation. It is quite possible that the Park would incur little to no cost, certainly a substantially lower cost than the $543,600 projected for paying employees or contractors to reduce the deer population in the Park.
Rather than paying licensed hunters to participate, a fee could be charged to assist the Park in covering its costs to manage the culling operation. Furthermore, state fish and wildlife agencies have already indicated that they are ready and willing to assist in any orientation, certification or other requirements necessary to use hunters to assist the National Park Service in achieving its management objectives for game populations in a safe and efficient manner. As a case in point,
the Colorado Division of Wildlife offered to manage the hunters for the Rocky Mountain National Park in a culling operation to reduce the elk population in the Park.
Using licensed hunters would also save the Park money in not having to remove the deer killed (as described in the "Disposal" section of Alternative C). Any licensed deer hunter has experience removing a deer he or she has harvested to use for personal consumption or for donation to a hunters-for-the-hungry program. Testing for chronic wasting disease can still be conducted and if a deer is found infected with the disease, then the Park can follow the National Park Service’s guidance for disposal.
The Plan/EIS also states that a managed hunt would be less efficient in meeting ungulate reduction project goals compared to sharpshooting because sharpshooters shoot over bait which increases the rate of success and the ability to be gender specific (does). Many hunters are familiar with shooting over bait since that practice is allowed in some states. But that is not the real point. Hunters can be just as efficient shooting over bait as a park employee or contract sharpshooter. Furthermore, hunters acting as sharpshooters can conduct the cull in the same manner as the Park envisions with the use of sharpshooters. That is, hunters could use spotlights, suppression devices and night vision equipment that the Park is allowing for its employees or contractors, equipment otherwise prohibited for hunting.
In rejecting a managed hunt, the Plan/EIS explains that the culling operation needs to be conducted near developed areas and potentially occupied buildings in order to be effective in reducing the deer numbers to the desired annual level. Although it is not clear how the topography of the Park limits public hunter access to more remote areas of the park, suffice it to say that areas opened to sharpshooters can be opened to licensed hunters participating in the culling operation. The Plan/EIS says that sharpshooting will take place when visitation is low or absent, a situation the Park can control regardless of whether federal employees, contractors, or licensed hunters are used. The necessary safety and security restrictions would apply to anyone involved in the culling operation.
Alternative C calls for the use of "qualified federal employees or contractors" who would be "experienced with sharpshooting methods and would have the necessary sharpshooting qualifications." The narrative does not explain what qualifications the employees or contractors must meet. However, there is likely to be a sizeable pool of licensed deer hunters who have the experience that would qualify them to participate in the culling operation. The sharpshooting qualifications are described as being "expected to coordinate all details related to sharpshooting actions, such as setting up bait stations, locating deer, sharpshooting, and disposition of the deer. An experienced deer hunter could easily meet those qualifications.
The Plan/EIS expressed concern that a managed hunt would not be successful in meeting population objectives because the Park would have to depend on an adequate number of hunters participating annually. The outcome would be an increase in the deer population if management actions failed or were postponed for a year. The Plan/EIS directs the reviewer to a study that analyzed managed hunts which concluded that as ungulate densities drop and management enters the maintenance phase, retaining adequate hunter numbers is difficult. This would likely not be an issue when hunters, like contract sharpshooters, would be able to hunt over bait. However, if hunter numbers should drop off over the 15 year period planned for the culling operation, the Park could augment the number of licensed hunters with park employees or contractors.
With respect to Alternative C as it relates to capture and euthanasia, we question the effectiveness of conducting a capture and euthanasia operation, especially at a cost of as much as $1000 per deer. Alternative C states that this approach would be taken in circumstances where sharpshooting would not be appropriate due to safety and security concerns. What guarantee does the Park have that deer removed from a "no shoot" zone would not shortly be replaced by other deer? It would seem that the method of killing deer as described in the Plan/EIS, particularly the use of bait stations, would provide for the level of success sought. Capture and euthanasia should be a last resort if the management levels over the 15 year period are not being met.
Our last comment concerns a statement in Table S-1, which provides a comparison of the alternatives. It states that handling of the captured deer will be minimized to reduce stress "in accordance with Humane Society recommendations." The NRA is very concerned that the Park would look to a non-governmental organization for guidance on handling wildlife over which the organization has no legal authority or responsibility. The Maryland Department of Natural Resources is the entity that has authority over the management of resident wildlife and it is to that agency that the Park should seek guidance on the protocols for capturing and euthanizing deer.
In summary, the NRA recommends that Alternative C, the Preferred Alternative, be amended to use licensed hunters as sharpshooters in lieu of park empoyees or contractors. The Park can work with the Maryland Department of Natural Resources and hunter-member organizations like the National Rifle Association to identify licensed hunters who are qualified or could be qualified as sharpshooters.
Again, thank you for the opportunity to comment on the Plan/EIS.
Sincerely,
Susan Recce
Director, Conservation, Wildlife and Natural Resources
National Rifle Association
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