Strategies to Manage Axis and Fallow Deer at Pt. Reyes National
Seashore and Environs, Including a Proposal to Designate such
Deer a Cultural and Historic Resource at PRNS
A Report By
John W. Grandy, Ph.D.
Senior Vice President for Wildlife
The Humane Society of the United States
2100 L Street, NW, Washington DC 20037
www.humanesociety.org • [email protected]
May 12, 2008
1. Introduction
In July 2006, the National Park Service (“NPS”) issued a final Environmental Impact Statement
(“EIS”) for the Point Reyes National Seashore (PRNS) Non-Native Deer Management Plan. The
EIS identified eradication as the preferred alternative for management of axis deer (Axis axis)
and fallow deer (Dama dama) within the National Park Service’s jurisdiction. This plan identified lethal removal and contraceptives as the method to entirely eliminate deer by 2021. The EIS
estimated populations of axis deer to be 250 and fallow deer to be 860. According to recent reports, more than 400 deer have been killed as of January 2008 (Fimrite 2008a, Rodoni Pers.
Comm.). The program has resulted in public opposition because of the waste of deer carcasses
left to rot and the inhumane methods indicated by deer found with wounds that would have resulted in slow, painful deaths (Fimrite 2008b). Moreover, these deer have become important cultural icons and ambassadors for wildlife with the local communities. Generations of school
children have marveled to see these animals and books have been written that celebrate their
beauty in the community and the Seashore (Carney 2008). These cultural values are something
that should be preserved in this community as they are in other (National Park Service) National
Seashore dominated communities where these values are prevalent.
This report assesses the current situation within the context of the scientific literature on managing negative impacts of naturalized non-native species and presents options for a humane approach for long-term management. As detailed below, axis deer and fallow deer are not good
candidates for complete eradication because the NPS and its contractors do not have access to all
properties where the deer are found, which is one of the prerequisites for undertaking an eradication program. Moreover, even if it were possible to completely eliminate these deer it would a
disservice to the community, its values and its citizens, and a betrayal of the values protected in
National Seashores and units of National Parks throughout the nation.
This report outlines the scientific support for use of a program of immunocontraception that
would stabilize and ultimately reduce populations of both deer species. Such a program should
be linked to a master plan that supports and insures the perpetuation of the populations of these
deer as a cultural and historic resource, and ensures their impacts are consistent with related biological objectives for Point Reyes National Seashore.
2. Axis and fallow Deer at Pt. Reyes National Seashore Are Not Good Candidates for
Eradication
Wildlife managers have long been called upon to control populations of vertebrate species that
have caused environmental impacts that are perceived to be deleterious to other species or the
environment. In the past, management efforts have involved large-scale removal of individuals
of species with the objective of eradication. Despite such efforts, as of 1995 no vertebrate species had ever been successfully eradicated on a continent (Bomford and O'Brien 1995). In this
instance “eradication” is defined as complete removal of a species by a time-limited campaign
(Bomford and O'Brien 1995). An eradication campaign without an endpoint is by definition ongoing control, and not eradication.
Bomford and O’Brien (1995) identify three conditions that are essential to achieve the eradication of a species. The essential criteria are (Bomford and O'Brien 1995):
•
•
•
Rate of removal exceeds rate of increase at all population levels;
Immigration Prevented; and
All reproductive individuals at risk
The plan for eradication of these deer species at Point Reyes National Seashore fails to meet
these three essential criteria. It also fails to meet one of three non-essential but desired criteria
for successful eradication, which is an amenable socio-political environment (Bomford and
O'Brien 1995).
2.1. Rate of Removal
It seems an obvious criterion for a successful eradication program that animals be removed more
quickly than they reproduce. Whether this condition can be met, especially when the species is
at low population densities, is not as obvious. Species can reproduce more quickly when at low
densities and locating individuals at low densities becomes exponentially more difficult and
more expensive (Bayliss and Yeomans 1989, Gogan et al. 2001).
The models in the EIS used to predict the time required and number of animals to be removed to
achieve eradication do not incorporate the increasing difficulty in locating individuals of each
species as they become more rare. Consequently the predictions of the date of successful eradication are not valid. These models are also not spatially explicit because they do not account for
the geographic distribution of animals. This is a critically important failing, because the EIS reveals that not all properties with fallow deer present will be accessible to the NPS for the purpose
of lethal removal (p. 22, 187). The 867-ha (0.87 km2) Vedanta Society property, which is contiguous with the Point Reyes National Seashore, is not open to allowing lethal control and supports the highest densities of fallow deer (p. 187), which are estimated at upwards of 80/km2 (p.
81).
Without access to the site that supports the highest densities of fallow deer, it is impossible for a
lethal control program to remove deer faster than they reproduce. Even if it were theoretically
possible to remove all deer outside this property, deer from the refugium of the Vedanta Society
property will continue to reinvade NPS property and require lethal management, beyond 2021,
the stated end date for the eradication program.
2.2. Immigration of Deer Cannot Be Prevented
The presence of a refugium for these deer within the Point Reyes National Seashore means that
immigration cannot be prevented. Deer will immigrate back into the Park from the Vedanta Society property and from other areas outside the Park that have been colonized by the deer already
(p. 81). Absent a deer-proof fence surrounding the entire Park and all inholdings where lethal
control cannot take place, fallow and axis deer are certain to return into the federally administered lands during and after the control program.
2
Figure 1. Map showing location of Vedanta Society property relative to high density and moderate
to low density occurrence of fallow deer. High density map from Fellers and Osbourn (2007) and
digitized in Google Earth.
2.3. Not All Reproductive Individuals Are Available for Management
The ongoing eradication effort does not meet the criterion that all reproductive individuals be
available for management, for the same reasons as above. A refugium is not only a source of
immigrants, but provides a location where many individual animals are safe from being captured
or killed as part of the eradication effort. Because the refugium is adjacent to and surrounded by
the project area, its population of deer cannot be separated from the Park lands without a tall
fence completely surrounding the property. Based on criteria for game farms, such a fence
would need to be 10 feet tall and completely enclose the entire Vedanta Society property. This
has not been proposed, and it would of course cause its own set of environmental damages that
have not yet been discussed.
Moreover, the area outside of the Park acts as a refugium as well. And the borders of this outside “refugium” would be far more expansive and uncontrollable than the Vedanta Society property; thus reemphasizing the futility and wastefulness of a National Park Service program to
exterminate these deer.
Those who undertake eradication programs know the importance of being able to locate and kill
every last individual. The owner of the New Zealand firm ProHunt, which was considered a
3
candidate firm to conduct the project at Point Reyes, was interviewed about the deer eradication
project. His comments included, “All you need is for one surviving pregnant doe and you’re
buggered” (Slobig 2007), meaning that the effort would be unsuccessful. The models of deer
response to eradication effort used in the EIS confirm this. In previously published articles,
those models predicted a rapid resurgence of the fallow deer population if even 20 does were left
when eradication efforts were ended (Gogan et al. 2001). Even if a contraceptive program were
concomitantly undertaken on the Vedanta Society property, some number of fertile deer would
return to the Park property because contraceptive programs are not 100% effective. And the effect of emigration from outside the boundaries (the outside refugium) of Point Reyes would
make the futility of an eradication objective complete.
The three essential criteria described by Bomford and O’Brien (1995) for the success of an
eradication program are not met in the case of these non-native deer at Point Reyes National Seashore. This is most clear for fallow deer, a conclusion that is even supported by the models relied upon in the EIS (Gogan et al. 2001). Gogan et al. (2001) conclude, “Complete removal of
fallow deer from PRNS is more problematic, given their greater number, wider distribution, and
range onto lands not administered by NPS.” Even with the proposed program of contraception,
fallow deer cannot be eliminated from Park property for any period of time. Furthermore, the
public outcry at the inhumane treatment of deer already killed as part of the program indicates
that the socio-political environment is not supportive of the project. On the other hand, contraception can be a major impediment to population growth even when significantly less than 100%
of the female deer are treated.
In another leading scientific journal, Meyers et al. (2000) present a different set of requirements
for consideration of eradication as a policy option:
•
•
•
•
•
•
Adequate funding is available;
Proponents have adequate authority to implement all necessary actions;
The biology of the species must make it susceptible to the control program (e.g., vertebrates that can be attracted to bait stations);
Reinvasion must be prevented;
The species can be detected at low densities; and
The ecosystem is managed following removal if the species removed is a keystone.
The Point Reyes non-native deer management plan fails to meet these criteria as well. The
ranges of both species extend beyond the Park’s boundaries and control, ensuring that the Park
lacks the authority to take all necessary actions, thereby guaranteeing that deer will repopulate
the area.
If eradication is not feasible, other options to address documented environmental harms caused
by non-native species include population suppression, slowing the spread of the species, and biological controls (e.g. promoting or introducing a predator or parasite of the species) (Myers et al.
2000). The urgency and extent of control methods for any established and acclimated species
should be commensurate with the documented environmental impacts of the species (as is being
accomplished with white-tailed deer at Fire Island National Seashore). Control efforts should
concentrate on reducing these impacts rather than on pursuing a goal of largely futile and economically wasteful eradication. In this case, the biological impact of the species can easily be
4
resolved through population control rather than elimination, and cultural and historic values of
these species can be preserved for the surrounding communities and the Seashore in perpetuity.
3. Axis and fallow deer are an Important Cultural and Historic Resource in Point Reyes
and Surrounding Environs, and Should be Managed as an Integral Component of Park
Resources
Fallow and axis deer were brought to Point Reyes National Seashore by a rancher in 1948, before the creation of Point Reyes National Seashore and Golden Gate National Recreation Area
(GGNRA). Millard “Doc” Ottinger received several of each species from the zoo, which had too
many. Ottinger set them free around Mount Vision for viewing with the idea that they might be
hunted if the population grew too large. Constant hunting kept the herds small until the Park
Service bought the Ottinger Ranch in 1965 and prohibited further hunting. The herds increased.
By 1976, after a series of hearings, the Citizens Advisory Commission to the GGNRA and the
Point Reyes National Seashore endorsed a plan for the park to limit each herd to 350 deer
through regular culling. However, that plan failed as the National Seashore administration redirected its culling funds to other functions. By 1984, the herds had grown to 750 fallow and 500
axis deer.
Since their introduction, the deer have naturalized and acclimated to the area where they are immensely popular with local residents and park visitors. Even Park Service officials have recognized the public’s enjoyment of the animals; a Park Service panel chairman in 1993 complained
that allowing the fallow and axis to live was “due entirely to public interest in viewing them.”
Indeed, generations of school children have enjoyed and grown to love these wonderful ambassadors of a wild and natural world.
Local residents, including many ranchers and hunters, have voiced their interest in maintaining
the deer population at Point Reyes. As businessman and former rancher, and fourth generation
resident, Fred Rodoni describes in a recent letter, “I grew up with these animals; I’ve seen the
yearlings frolic and play on sunny afternoons. I’ve seen the bucks clash for superiority. My
cousin and I risked our own safety to separate two fallow bucks hopelessly tied together with
plastic jay rope discarded by a careless rancher. I’ve shot and eaten a number of deer in my life.
Yet, I strongly oppose the Park Services cruel and useless policy to exterminate these majestic
animals” (Rodoni 2008 (attached)).
These sentiments and the history join the issue. There are numerous non-native species in Point
Reyes National Seashore and in other parks across the country. In Point Reyes we can start with
thousands of livestock, as well as others. The ones the Park Service wants to eliminate, they
brand as “exotic” or “invasive” to encourage negative attitudes. The ones they do not want to
campaign against, they just ignore. So Point Reyes officials ignore the cattle and numerous naturalized non-native species, while they launch a destructive campaign to eradicate fallow and axis
deer (See Rodoni 2008, attached).
The truth is that the deer preceded the Point Reyes National Seashore to Marin County by many
many years. The deer are important to the local community, to its culture and its identity and its
5
history. Trish Carney (Carney 2008) has just published a major photographic essay of these
deer. In other National Seashore units and Park units where locally important animal communities are established before the Park, they are often accommodated or grandfathered into the enabling legislation, often with the imprimatur that the animals are important “cultural and historic
resources”. This is what happened with the wild horses when Assateague Island National Seashore was created (September 21, 1965, Public Law 89-195). Similarly, when the Superintendent of Cape Lookout National Seashore would not accept an equivalent solution to preserve its
wild horses, Congressman Walter Jones (NC) added specific provisions to the enabling legislation for Cape Lookout National Seashore to insure that its wild horses would always have a
home on the Shackleford Banks portion of Cape Lookout (March 10, 1966, Public Law 89-366;
August 13,1999, Public Law 105-229).
This is exactly what should happen to ensure the protection and compassionate management of
fallow and axis deer on Point Reyes in perpetuity. I offer brief but workable legislative language to accomplish this goal at the end of this paper.
4. Contraception Can Be Used to Manage Fallow and Axis Deer Populations
The EIS comes to the conclusion that using contraception alone to eradicate free-ranging populations of large ungulates is unlikely to succeed. However true this may be, it is, as we have demonstrated, equally likely that the Park Service plan for eradication will fail. This emphasizes the
National Park Service’s need to develop a management plan that ensures the perpetuation and
compassionate management of axis and fallow deer as a cultural and historic resource while
meeting biological objectives for vegetation at Point Reyes National Seashore.
Moreover, the current condition differs from that analyzed in the EIS based on the number of
deer already killed as part of the program. Furthermore, new information about the efficacy of
contraceptive approaches on deer populations is available (Patton et al. 2007, Rutberg and
Naugle 2008). The published and forthcoming scientific literature indicates that an immunocontraceptive approach could be used to manage the fallow and axis deer populations found at Point
Reyes National Seashore.
4.1. Immunocontraception with Porcine Zona Pellucida
Immunocontraception is a process by which the immune system of a mammal is stimulated to
attack elements of the reproductive system, thereby inhibiting pregnancy. The most well-known
and tested immunocontraceptive agent is porcine zona pellucida (“PZP”) (Patton et al. 2007).
All mammalian eggs have an outer layer known as the zona pellucida. Antigens from the zona
pellucida of pigs are isolated and injected into females of other species with an adjuvant (Patton
et al. 2007). This stimulates the development of antibodies in the recipient, which then interact
with the zona pellucida of their own eggs, blocking fertilization by sperm (Paterson and Aitken
1990).
PZP is delivered with an initial injection with Freund’s Modified Adjuvant, and a follow-up injection with Freund’s Incomplete Adjuvant (Deigert et al. 2003; Lyda et al. 2005). Freund’s
Modified Adjuvant is non-toxic to humans, with no known pathologies associated with it, so
6
animals could be treated safely, without marking as is done successfully for white-tailed deer on
Fire Island National Seashore.
PZP was first shown to block pregnancy in white-tailed deer in captivity (Turner et al. 1992,
Turner et al. 1996). Subsequent studies showed effective delivery to free-ranging deer
(Kirkpatrick et al. 1997, Curtis et al. 2002, Naugle et al. 2002; Rutberg et al. 2004). These formulations required repeated initial shots and annual boosters, so timed release delivery systems
have been developed (Turner et al. 2007, Turner et al. 2008). In wild horses an initial injection
followed by a booster of timed release PZP pellets achieves two years of fertility control (Turner
et al. 2007).
Experiments with fallow deer in captivity have shown reduction in fertility with treatment using
PZP, with 0% fertility achieved in a herd after treatment of 59 of 61 adult females (Deigert et al.
2003). Treatments were given with Freund’s Modified Adjuvant or Freund’s Incomplete Adjuvant with contraception caused by either three injections with Freund’s Incomplete Adjuvant or
two injections, with Freund’s Modified Adjuvant used in the first injection and either adjuvant
used in the second. PZP has also reduced fertility of axis deer in captivity with moderate effectiveness when delivered with muramyl dipeptide (MDP) and Freund’s Incomplete Adjuvant
(Kirkpatrick et al. 1996).
PZP can reduce fertility in captive herds, arresting population growth and with continued application resulting in long-term population declines. Field studies have now shown that management of deer populations with PZP immunocontraception can be achieved (Naugle et al. 2002,
Rutberg and Naugle 2008). Fire Island, including the National Seashore of the same name, is a
22.5 km2 island in New York. Native white-tailed deer are found in abundance on the island and
a hunt to control population size was stopped by public outcry and a lawsuit (Rutberg and
Naugle 2008). A program of immunocontraception with PZP was initiated to address legitimate
concerns about habitat degradation resulting from deer abundance. Deer were not marked or
tagged and all vaccines were delivered remotely using darts (Rutberg and Naugle 2008). The
darts contained a dye to mark the deer to help avoid retreatment. In the most closely monitored
portion of the island, the deer population decreased 10–11% per year during the program. These
population studies were conducted by an independent entity, the Biological Resources Division
of the U. S. Geological Survey, of the U.S. Department of the Interior. Similar population declines were obtained in smaller areas where white-tailed deer were treated with PZP (Rutberg et
al. 2004).
Rates of free-ranging deer increase or decline during PZP vaccination programs are directly related to the proportion of deer that are treated each year (Rutberg et al. 2004). For most ungulates, populations decline when more than 60% of females are treated with a contraceptive
(Garrott 1995, Rutberg et al. 2004). These studies indicate that immunocontraception can stabilize and reduce populations of wild ungulates at the landscape scale.
An immunocontraceptive approach to managing the impacts of these deer at Point Reyes National Seashore could be effective by concentrating treatment in those areas with the highest density of non-native deer. These areas are also where the influence of the deer on the environment
is greatest (Fellers and Osbourn 2007). These areas differ for axis and fallow deer.
7
4.2. Axis Deer
Apparently, the original population estimate of axis deer (250) was excessive or the NPS contractors have killed these deer far faster than anticipated in the EIS. Indeed there now seems to
broad agreement that the axis deer population is below 20 and perhaps even below 10 (Rodoni
Pers. Comm.). Under this circumstance, stabilization and gradual decline (or increase) of axis
deer populations should easily and quickly achieve biological goals since these deer are grazers
similar to cattle and feed predominantly on exotic forbs and grasses, consuming marginally more
forbs than cattle (Elliott and Barrett 1985).
Axis deer browse limited quantities of shrub vegetation — less as a proportion of diet than blacktailed deer (Elliott and Barrett 1985). Furthermore, the most significant overlap in preferred forage with black-tailed deer is an exotic plant, Plantago lanceolata (Elliott and Barrett 1985). Reduction in axis deer, if followed by increase in black-tailed deer as predicted in the EIS, would
increase browsing pressure on native shrubs and forbs and decrease grazing pressure on exotic
grasses and forbs preferred by axis deer. According to the EIS, axis deer are found in greatest
density in two disjunct areas that appear to be coastal prairie and agricultural grasslands (Figure
2). According to the map presented in the EIS, axis deer are found in a roughly 3 km2 area at the
southern tip of the peninsula and 5 km2 area in the northern part of the peninsula (areas digitized
by overlaying EIS maps in Google Earth). The EIS also discloses that axis deer are found at low
density elsewhere, including outside the Park’s jurisdiction.
Given the low population, treatment of nearly all female axis deer in these areas should be logistically feasible because of the relatively small habitat area in which most are found (Rudolph et
al. 2000). Moreover, if the tagging requirements can be waived based on the highly successful
experience with immunocontraception at Fire Island National Seashore, the first year would require only vaccination and use of marking darts to mark individuals for females for which contraception would be desirable. Subsequent boosters could be administered remotely and the
small number of fawns in future years would be vaccinated remotely, as well.
Currently, however, given the apparently severely depleted population, it is highly likely that no
contraception or population control should be used on the axis deer for the foreseeable future.
8
Figure 2. Distribution of high density areas of axis deer (Axis axis) on Point Reyes National
Seashore.
4.3. Fallow deer
Fallow deer are distributed much more widely across NPS lands, inholdings, and outside of Park
boundaries. The highest densities, however, occur in the southern Olema Valley in the pastoral
zone and adjacent Vedanta Society property. The high density area (Figure 1) consists of approximately 25 km2, based on the map provided by Fellers and Osbourn (2007). Within this
zone, soil disturbance and vegetation damage at lek sites constituted 1.1% of the total area surveyed in the Olema Valley chosen to represent high fallow deer density (Fellers and Osbourn
2007). Within the low/medium density zone, lek sites constituted 0.1% of the total area surveyed. In the zone with lower fallow deer density, the size of leks, and the number and depth of
rutting pits within leks, decreased dramatically (Fellers and Osbourn 2007). These observations
suggest that management effort, when necessary, should be concentrated where densities are
highest and that vegetation damage and erosion associated with lek sites should decrease both by
reduced population size and behavioral changes resulting from lower densities.
The EIS estimated the population of fallow deer at 860 animals. As is the case with axis deer,
the original population estimate was excessive or the NPS contractors killed these deer far faster
than anticipated in the EIS. Indeed there now seems to broad agreement that the fallow deer
population is less than about 160 individuals (Rodoni Pers. Comm.).
An immunocontraceptive program would require vaccination of approximately 80 females for
100% treatment, which should make contraception an easily viable alternative for slowing popu-
9
lation growth and maintaining a reduced population over time. A reasonable assumption is that
at least half of these would be found in open habitats and forest edges of the Olema Valley and
other grassland and scrub habitats (based on the densities of 80 deer/km2 reported for the Olema
Valley). The other half would be found in less accessible forested landscapes. Without a requirement for capturing and tagging, annual treatment of does would take approximately 6 hours
per deer in the pastoral zones, and 10 hours per deer in more difficult landscapes. Time for
treatment would likely be far shorter in the pastoral zones; treatment per free-ranging whitetailed deer at other sites described above took less than two hours per deer (Naugle et al. 2002,
Rutberg et al. 2004).
I present these estimates only for informational purposes and use in future planning, as the current estimate (160) of the fallow deer population is well below the goal of 350 total deer contemplated in the EIS, suggesting that no population control will be necessary or appropriate for some
time.
4.4. Costs and Benefits of a PZP Based Immunocontraception Vaccination Program
The PZP vaccine and darts are relatively inexpensive; actually less than $50/treatment (primer
dose @ $21 + booster dose @ $21 + 2 darts @ $3.; and that is only for the first year. Thereafter
the cost is about $25./year.) the primary cost in such programs is labor to administer the vaccine
(Rutberg 2005). At Fire Island National Seashore, where deer were accessible and capture for
tagging was not necessary, treatments took 1.4 hours per deer (Naugle et al. 2002). At another
site, contraceptive darting took 1.6 hours per deer (Rutberg et al. 2004). The EIS assumes 6
hours per inoculation (p. 37). Even at 6 hours per doe, treatment of 80 does would take 60 person-days per year. Moreover, significant savings would be ensured if it were the case that deer
were not subject to immobilization and tagging based on the successful precedent of contracepting white-tailed deer with PZP at Fire Island National Seashore and the demonstrated safety of
the vaccine. If population numbers for axis and fallow deer are as low as some believe, the
chances of a PZP vaccination program succeeding rapidly would be greatly increased.
Finally, Fire Island shows that the use of the PZP vaccine has other advantages as well. At Fire
Island National Seashore following a deer hunting season to reduce the deer population, the Fire
Island beach community was polarized and in a state of turmoil (Rutberg and Naugle 2008).
Some wanted to kill deer; some wanted to save them all. In that atmosphere, community leaders
supported by the Fire Island National Seashore decided to ask if Drs. Jay Kirkpatrick and John
Turner, working with The Humane Society of the United States (HSUS), would begin an immunocontraception program to humanely control the population of white-tailed deer. We immediately assented, and the program has been and continues to be a major biological success.
However, just as important has been the collateral benefit that humane control of deer numbers
has brought the community together in a way that no one would have predicted. The people who
did not like deer, like the program; the people who love the deer, also like the program. And
with this unity, the community has continued to show its support, by contributing monetary resources to help make the program possible.
It is my hope that such an outcome can occur here, as well.
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5. Conclusion
Undertaking immunocontraception represents a commitment to indefinitely managing the fallow
and axis deer at Point Reyes National Seashore. It seems, however, that a commitment to indefinite management has already been made by undertaking an eradication program that is almost
certain to fail. Moreover, the deer themselves offer cultural, historical and educational values to
the Marin County area that are worthy of fostering and preserving in their own right. A contraceptive management program will allow those values to flourish while achieving and maintaining a desired population level for each species. Moreover, such a contraception program has the
potential to be fully applied on inholdings within the Park and extended through non-federal cooperators to deer that have expanded their ranges beyond the Park boundaries. By doing so, an
immunocontraceptive approach has the potential to achieve the biological goals desired by Park
managers in a sustainable manner and over a greater geographic area.
Adoption and funding of a contraceptive approach for management of axis and fallow deer at
Point Reyes National Seashore depends on the level of institutional and political support that can
be generated for it. This review illustrates that a nonlethal approach is feasible and for the areas
of highest density, essential to gaining access to inholdings. The three objections to use of immunocontraception expressed in the EIS no longer apply to the current situation.
First, the EIS claimed there were too many deer to implement a contraceptive program. For better or worse, the number of deer has already been reduced to perhaps as few as a combined total
of 190 for both species. Although a logistical challenge, as long term population goals for each
species are determined, it should be possible to treat upwards of 90% of axis and fallow does using resources that would have otherwise been dedicated to tracking down and killing all deer
(bucks included). Booster shots can be delivered remotely and repeated blood draws to determine hormone levels are not needed for use of the PZP vaccine (Kirkpatrick et al. 1996). In doing so, an immunocontraceptive approach has the potential to achieve the biological goals
desired by Park managers (e.g., reduction in ground disturbance at leks, decreased competition
with native ungulates, reduced vegetation disturbance) in a sustainable manner and over a greater
geographic area.
Second, the EIS claimed that the variable breeding seasons of axis deer preclude use of a contraceptive approach. This is incorrect. Indeed, The HSUS experience shows that a PZP vaccination
program can be started at any time with the adjuvants that we now use, regardless of the breeding
biology of axis deer. PZP is currently delivered with an initial injection with Freund’s Modified
Adjuvant, and a follow-up injection with Freund’s Incomplete Adjuvant (Lyda et al. 2005).
These adjuvants avoid the problems associated with Freund’s Complete Adjuvant, which was
used in previous research (Deigert et al. 2003).
Third, the EIS claimed that a contraceptive program could not reduce the population of each species to 350 individuals. Axis deer are already far far below this threshold (perhaps 30 or less)
and a conscientiously applied PZP contraceptive program could easily stabilize the population at
a desired level. Fallow deer are now at an estimated 160 individuals (or fewer), and likewise
could be managed to a desired population level through a PZP contraceptive program. This
would represent a large-scale effort, but would be feasible, especially given the recent develop11
ment of timed release PZP vaccine pellets (Turner et al. 2007). With cooperation from inholding
landowners, institutional commitment, and adequate funding, such a program has a greater possibility of long-term attainment of biological goals for the Point Reyes National Seashore and
surrounding areas than does continuing a futile and divisive lethal management program into the
indefinite future.
Finally, deer preceded Point Reyes National Seashore to Marin County by many many years.
Axis and fallow deer are important to the local community, to its culture, its identity and its history. Trish Carney (Carney 2008) has just published a photographic essay of these creatures, and
the community is uniting to urge an end to the killing of these animals. Given the low number of
deer remaining and the advances in immunocontraceptive technology through PZP, the National
Parks Service should immediately end the lethal control of deer at Point Reyes National Seashore
and develop a comprehensive management plan that is designed to achieve biological vegetative
objectives, while supporting a genetically robust populations of these deer at PRNS and environs, in perpetuity. In other National Seashores and Park units where locally important animal
populations or activities precede the Park, they may be accommodated or “grandfathered” into
the enabling legislation, often with an imprimatur designating the favored animals as important
“cultural and historic resources”. This is what happened with the wild horses when Assateague
Island National Seashore was created (September 21, 1965, Public Law 89-195). And when the
Superintendent of Cape Lookout National Seashore would not accept something similar to preserve its wild horses, Congressman Walter Jones added specific provisions to the enabling legislation for Cape Lookout National Seashore to insure that its wild horses would always have a
home on the Shackleford Banks portion of Cape Lookout (March 10, 1966, Public Law 89-366;
August 13,1999, Public Law 105-229).
This is exactly what should happen to ensure the protection and compassionate management of
fallow and axis deer in and around Point Reyes National Seashore. Although it could be expanded and embellished, the following language, or something similar, should accomplish the
objective if attached to legislation that passes and is signed into law:
Notwithstanding any provision of law, the National Park Service is hereby prohibited from
expending funds or conducting activities for the purpose of killing axis or fallow deer at
Point Reyes National Seashore as part of any program to control non-native species and is
hereby directed to prepare and implement, with appropriate community involvement, a
comprehensive plan to limit ecological change caused by these species to biologically compatible levels through humane non-lethal methods. Fallow and axis deer represent a cultural and historic resource in Point Reyes National Seashore and surrounding areas, and
they should be subject to humane and compassionate management that preserves these
animals with robust genetic viability in perpetuity. The comprehensive management plan
should reflect that goal.
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“Fallow and Axis Deer Should Be Saved”
by Fred Rodoni, Jr.
The Fallow and Axis deer have co-existed beautifully with the native black tail for 60 years. There is
very little competition between them because there is so much food and they have very different diets. From Mt. Vision to Bolinas, the grass is so tall you can’t even see the deer. Why do you think
the Vision Fire burned 8,800 acres in less than 24 hours? All Axis and Fallow and Black-tail are in
prime fat condition. There could be three times as many deer and there still would not be a food
shortage.
I was born here in 1947, about the same time the Axis and Fallow were introduced. I leased land from
the Park Service for twenty years for a small scale beef cow and calf operation. My ancestors were
one of the first ranching families to settle in the Olema Valley, arriving in 1864. I’ve been all over
this land even before it was a park and to this day I’m out in the park all year long. I do have a
wealth of firsthand knowledge. I grew up with these animals; I’ve seen the yearlings frolic and play
on many a sunny afternoon; I’ve seen the bucks clash for superiority. My cousin and I risked our own
safety to separate two Fallow bucks hopelessly tied together with plastic hay rope discarded by a careless rancher. And, I’ve shot and eaten a number of deer in my life. Yet I strongly oppose the Park
Service’s cruel and useless policy to exterminate these majestic animals.
Already over 700 animals have been slaughtered, by Park Service count, and those remaining will
likely be killed this spring, even though the Park plan said there would be a gradual reduction over 12
years. The Park Service says their extermination plan is necessary to preserve the natural biological
systems. Yet, they continually ignore the fact there are 10,000 non-native Holstein and Angus cows
and a couple hundred horses in the park. Thousands of acres of natural flora and fauna habitat are
plowed every year to plant non-native hay silage and there are hundreds of acres of Eucalyptus
groves and other non-native plants. The Park Service is proud of its own non-native Morgan horse
ranch. The Axis and Fallow deer are so far down the list on environmental impact that it’s mind boggling they have been singled out for extermination. Actually, Fallow deer were first introduced to this
country by George Washington at Mt. Vernon. Surely they deserve more respect! Over the years,
many ranchers and outdoorsmen have found large numbers of dead deer left in fields or dumped in
remote gullies. This is the dark side of the story.
The bright side of the story is that so many people have treasured these animals over the years. One
of my 90 year old father’s happiest moments in the last ten years of his life has been to visit my
mother’s grave in Olema and see the Fallow deer in the Olema Valley. Sometimes they wouldn’t be
there and he would worry something had happened to them. I would tell him not to worry, they
move around depending on the season. I don’t have the heart to tell him what’s happened now.
I am one of many local residents who are letting our elected representatives know that killing the
remaining deer is cruel, illogical, and unnecessary and urging them to put a stop to the upcoming
slaughter this spring. Please join us in our quest to save these beautiful and harmless animals.
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