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John Eveland Answers PA Game Commission Claims
On May 11, 2011, the Pennsylvania Game Commission (PGC) released a rebuttal to my independent investigation of the agency's deer management program. In the first paragraph of PGC's rebuttal, the agency stated that "...there have been many mistakes and errors on the part of Mr. Eveland, as well as completely false allegations." I will, herein, respond to PGC's rebuttal, as well as reaffirm my investigative conclusions regarding the PGC's management of the Commonwealth's deer herd.
In the second paragraph, PGC stated "...the debate over deer management has existed in this state since the first antlerless deer season was held in 1923. So, in a large sense, Mr. Eveland is simply the latest to play a role that many others have over the past nine decades; that of proclaiming the imminent demise of our deer herd."
Permit me first to state that if the PGC considered my claims to be simply that of another disgruntled sportsmen, it is unlikely that Mr. Feaser and the PGC would be responding with a 5-6 page rebuttal.
Secondly, whereas it is true that deer numbers have been, and will likely continue to be, the topic of hot debate between sportsmen and the PGC, I have not involved myself in this debate from my early years of hunting in the 1960s and my scientific research of the statewide bear and elk populations in the late 1960s and 1970s – until now.
My scientific studies were conducted while at The Pennsylvania State University, and were supported and funded by the U.S. Department of the Interior's Fish and Wildlife Service, Pennsylvania Department of Forest and Waters (now DCNR), and the PGC. A description of my bear and elk research appears on a website sponsored by the Allegheny County Sportsmen League (www.acsl-pa.org
As a point of historical fact, about a decade ago I was asked by the state's most prominent senator at that time to accompany him to a presentation by Gary Alt and to comment on the PGC's proposal to reduce the deer herd. Without getting into the technical part of my critique, I summarized by stating to the senator that the PGC was planning to systematically reduce the deer herd, hunter harvest success would dwindle, sportsmen would become increasingly disgruntled, and Gary would be forced to leave the agency. These things happened. It was not until 2007 that I again became involved with the issue, realized that things were not as the PGC was telling sportsmen and elected officials, and began to uncover the real reason behind herd reduction.
In this regard, I am not simply another disgruntled hunter, for I have amassed extensive original documentation that demonstrates that Pennsylvania's deer herd is being mismanaged, not in the interest of sportsmen, but instead to satisfy the special-interest needs of others. This I have discovered to be a flagrant violation of the Title 34 Game Code.
In their third paragraph, PGC stated, "I do not believe anyone can pretend that a solution could ever be reached that will please all interests...who want to return to the days of seeing hundreds of deer a day while afield."
This issue is not about "seeing hundreds of deer a day while afield.". It is about serving the best interest of sportsmen in their recreational pursuit of game. Regarding the deer herd, that simply means providing a huntable number of deer, as required by state law under Title 34 (The Game Code).
In the fourth paragraph, Mr. Feaser referred to the need for science to determine deer management policy, stating, "Despite the complexities, the procedures and techniques used by wildlife management professionals involved in the present scientific community are irrefutable, no matter how dry, boring or confusing they may be to you and me."
First, I would refer you to my comments under Item 1 (above). The PGC does not hold an exclusive right to make scientific assessments, whereas they do have the ability to unilaterally deploy their agenda (whether based on sound science or not) with impunity regarding wildlife management policy. Therein lies the problem, and the need for personnel in the agency whose goal is to adhere to the chartered mission of the PGC instead of their personal agendas.
Secondly, wildlife management is not intended to be based solely on scientific principles. Management is defined as a mix of art and science. That is why scientists are not often the decision-makers in industry and government. Management balances science with the needs of society, economy, environment, the corporate bottom-line, and any number of variables. As an example, the Detroit car industry could use its best scientists and engineers to design every functioning part of an automobile, to attach every door and window with utmost perfection, and to place every bolt and rivet to micrometer specification – but an Edsel will still be an Edsel.
Using science as an excuse to reduce the deer herd is irresponsible. Unfortunately, Mr. Feaser, "science" can also be used as a means of intimidation toward advancing one's goals and agendas. The PGC was chartered to serve the interests of the People – not the best interest of scientists nor the statistical principles of academicians.
In paragraphs five and six, the PGC claimed that there is no ulterior motive for reducing the deer herd. PGC stated: (a) "The Game Commission's desire to achieve these objectives led to increased hunting pressure on deer populations, not an alliance with "special interests" as claimed by Mr. Eveland. There was no conspiracy, nor secret meetings." (b) "Every step of the agency's herd reduction plan was discussed and adopted in public meetings." (c) The bottom line is Mr. Eveland's allegations that the Game Commission's deer program was designed by some secret cabal are false."
Regarding the PGC's first point (a),
A January 15, 1998 document entitled a "Summary Review of a November 21, 1997 Workshop, Rachel Carson State Office Building, Harrisburg, Pennsylvania" describes a one-year (1996) pilot assessment to determine if the Pennsylvania Department of Conservation and Natural Resources (DCNR), Bureau of Forestry (BOF) could benefit from enrollment in a newly-designed Green Certification Program toward enhancing the marketability and sales (domestic and overseas) of DCNR's lumber and wood products. The assessment was conducted by a Mr. Bryon Shissler (Natural Resources Consultants, Inc) (NRC)) as a representative of Scientific Certification Systems (SCS) of Oakland, California. (Note that NRC was a one-man operation consisting of Mr. Bryon Shissler, who later was joined by Gary Alt following his exodus from the PGC.) SCS had been certified by the newly-founded Forest Stewardship Council (FSC) of Bonn Germany as the U.S. salesman of the Green Certification award. (Please visit www.acsl-pa.org
for a comprehensive review of these Green Certification documents.)
Herein lies the problem. Mr. Shissler decided to base his approval of the annual audit on DCNR's ability to reduce the deer herd. Because DCNR does not have the state-chartered ability to regulate hunting seasons or game populations, the agency could not be awarded the Green Certification award unless the PGC agreed to reduce the deer herd – annually, drastically, and permanently. By 1998, PGC had agreed to comply.
Quoting the above-mentioned document: "The workshop focused primarily on a pilot project whereby 1.2 million acres of Pennsylvania state forest lands underwent a certification review by Scientific Certification Systems (SCS), a national certifier accredited by the Forest Stewardship Council (FSC). The on-the-ground review was preformed by National Resource Consultants, Inc., a Pennsylvania-based organization, on behalf of SCS."
Further quoting the document, "...the Commonwealth of Pennsylvania announced a few days prior to the workshop that it will proceed with certification of the 1.2 million acres subject to the pilot project, and will submit the remainder of the 2.1 million acre state forest system to a certification evaluation in 1998."
Subsequently, DCNR was awarded its first Green Certification stamp-of-approval by SCS in November 1998. Quoting the lengthy certification document: "The Pennsylvania Department of Conservation and Natural Resources, Bureau of Forestry: Certificate Awarded (November, 1998) by Scientific Certification Systems, Oakland, California."
Quoting further: "...operations accredited by the Forest Stewardship Council";
Crucial to the award were the following statements:
• "If (deer) populations are not reduced, the ability of both public and private landowners in Pennsylvania to meet or maintain FSC standards will be jeopardized."
DCNR followed with the agency's own Deer Management Plan, and stating from the document: "(DCNR) has undergone a third-party review of the sustainability of the forest ecosystems on these lands, a process known as Green Certification. This process found that the primary factor threatening the sustainability of these forests is overbrowsing of vegetation by white-tailed deer. In response to this threat, and as a condition for DCNR to retain "Certification," the auditors required the following CAR (Corrective Action Requests:"
Further quoting the document: "SCS acknowledges that solutions to the Pennsylvania deer density problem cannot be designed and implemented solely by BOF because currently the Pennsylvania Game Commission regulates deer seasons..."
In the document, DCNR proceeds to outline PGC's deer reduction actions, including:
• the creation of the Deer Management Section in 1998 with Gary Alt as supervisor.
• the switch to the concurrent buck/doe season.
• numerous other changes to the deer program, and especially the new antler restrictions.
Quoting the document: "All of these initiatives have been successful at providing tools for increasing the antlerless deer harvest. Increased restrictions for antlered bucks made it harder to harvest a buck so hunters were more apt to harvest an antlerless deer instead." This last quote indicates that antler restrictions were a concoction to frustrate hunters who, when not seeing a legal buck, would divert their attentions to killing more does.
To demonstrate the extreme desire to go even further and faster with herd reduction, DCNR recommended additional considerations for the PGC, quoting: "early extended rifle season, multiple permits per hunter per DMAP area, eliminate the tagging requirement before harvesting multiple deer, party hunting, unlimited permits, use of bait to entice deer, night hunting, the use of semi-automatic sporting rifles, dogs, and professional control of deer."
Regarding DCNR's second point (b),
that "Every step of the agency's herd reduction plan was discussed and adopted in public meetings," I refer to a document entitled "Findings and Recommendations of the Pennsylvania Deer Management Working Group, Presented to the Executive Director and Board of Commissioners, Pennsylvania Game Commission, January 2000 by Scot Williamson."
This group had been concocted by the PGC to give the appearance that the about-to-be-announced deer reduction program was the legitimate result of a third party review team. Although the Deer Management Working Group (DMWG) consisted of a variety of interests including sportsmen and farmers, it was chaired and dominated by five staunch promoters of deer reduction who had all been principal speakers at Audubon's 1999 reduce-the-deer-herd conference in Harrisburg: Scot Williamson, Bryon Shissler, Cindy Dunn (the Executive Director of Audubon Pennsylvania), Susan Stout, and Ben Moyer. Additional speakers who supported deer reduction at the 1999 Audubon deer conference were John Oliver (Secretary of DCNR), Calvin DuBrock (Chief of the PGC Bureau of Wildlife Management), and Gary Alt. Hence, it was a predetermined conclusion that the DMWG would recommend herd reduction, and, in this regard, it was Scot Williamson and his cohorts who designed the new deer-reduction program (likely under collaboration with Calvin DuBrock and Gary Alt), including: the concurrent buck/doe season, changing from a county-based system to Wildlife Management Units, the hot-spot/DMAP system, and other herd-reduction methods.
It should be noted that this same Scot Williamson – the man who was a herd-reduction proponent and speaker at Audubon's 1999 deer-reduction conference, who was chairman of the DMWG, and who is credited with the 1998-2000 design of the PGC's deer-reduction program – was awarded the $95,000 contract in 2009 by State Representative David Levdansky to conduct the fraudulent audit of the PGC's deer reduction program in collusion with Timothy Schaeffer, the Executive Director of Audubon Pennsylvania. In very clear words, Mr. Feaser, the designer of the deer-reduction program was awarded the contract to conduct an audit of his own program. This action is likely a serious violation of state law, and nullifies any credibility of the audit.
Regarding the third point (c),
On January 9, 2001, outdoor writer Dave Drakula published an article entitled "Politics and Public Opinion Impact Deer Management." The following quotes were taken from this newspaper account of Green Certification versus deer herd reduction:
• "Despite claims to the contrary, political considerations do play a role in Pennsylvania's deer management program."
In March 2002, Dave Drakula authored another newspaper article in the Greensburg Tribune Review, entitled "Deer or Trees" with the subtitle "Follow the money...Game Commissioner confirms deer program is forestry issue." Quoting from the article:
• "Game commission board member, John Riley, has confirmed that the game commission's proposed deer management plan to be voted on April 9 is not even based on game commission policy."
• "According to the agency's mission statement, the game commission is charged with management of wildlife, not forestry issues."
• "Commissioner Riley explained that the deer management plan is actually a forestry bureau issue based on the state forests "Green Certification" and the management of the forestry issues, not the deer."
• "The game commission is pushing the deer management plan because the state needs the deer herd reduced; and that's what this is all about, forestry, not wildlife, Riley said."
• "The certification of the state's forests made the timber (primarily cherry) much more valuable and also with the official certification rating, marketable for export to England and throughout Europe, which creates a sizeable income to the state in timber sales."
• "The same certification that has been granted to the state forest system has been threatened with removal if the deer population, considered by foresters as a threat to trees, is not significantly reduced."
• "Riley explained that since the Bureau of Forestry has no jurisdiction over the deer herd, but the game commission does, pressure has been put on the game commission to come up with a plan to save the state money by culling more deer. The state needs to save the forest certification that makes a lot of money for the state and the state doesn't want to risk losing those revenues."
• "Riley was just appointed to the game commission board in January ... his swift appointment was no mistake ... he now brings the number of commissioners to seven an odd number that can swing the vote in favor of the antler restrictions and high antlerless deer license allocations."
• "Riley, a certified public accountant, says there is no way to calculate the numbers on how to manage the deer herd in a way that will reduce the population or even-out the buck to doe ratio. It doesn't matter anyway, said Riley. This is a forestry issue and not a deer issue."
Finally, on April 11, 2011 at the Commissioner's meeting in Harrisburg, Commissioner Tom Boop stated as quoted in a Pittsburgh Tribune-Review newspaper article: "I'm just really tired of catering to the timber industry on wildlife. Whether people like it or not, we are about providing recreational opportunities for hunters, Boop said."
Given the extensive stack of documents, the PGC must be delusional to state that deer management has not been manipulated to achieve the agendas of a few special interests. It is time for the PGC to, instead, represent the interests of those the agency is charged to serve – sportsmen.
In paragraphs 7-12, the PGC challenges my critical assessment of the accuracy and veracity of the agency's annual deer harvest estimates. Quoting PGC, "Although he references scientific sources for his numbers, Mr. Eveland incorrectly identifies the population he calculated. He claims to have calculated a "post-hunting season" deer population when he actually calculated a "pre-hunting season" population."
For the curious reader, my assessment, calculations, and scientific sources are available in the report entitled "An Independent Assessment of the PGC's Estimated Annual Deer Harvests", as posted on www.acsl-pa.org.
To summarize my findings regarding the PGC's claim of harvesting 316,240 deer in 2010, permit me to provide the following analysis.
The PGC claims that the deer population has been stable for the past 5-6 years. Therefore, in order to maintain a stable population, total annual mortality must equal the annual recruitment of fawns into the population. Using Christopher Rosenberry's numbers that hunting represents 71% of total annual mortality, then total mortality and fawn recruitment must equal 445,408 deer. Using scientific sources, as acknowledged by Mr. Feaser, it would require a population of 1,272,594 deer to support such fawn production. This 1,272,594 deer that would be required to produce 445,408 fawns represents the overwinter (post-hunting season), pre-birth population. Once the fawns are born, add 445,408 deer to yield a summer (pre-hunting season) population of 1.7 million deer.
Considering that the PGC erroneously claims that my 1.7 million deer is inaccurately depicted as a post-hunting season (overwinter) calculation is not surprising. The PGC does not consider hard numbers, the actual size of the deer population, nor deer densities in their attempt to manage the state's deer herd, but instead the agency adjusts the size of the herd based on impacts – such as determining the annual number of antlerless licenses to be allocated based on the numbers of indicator wildflowers in the forest, including Indian cucumber root, trillium spp., and Canada mayflower. As mentioned in my published assessment, such arbitrary and qualitative methods to determine herd size permit lowering the deer herd to any degree without quantitative accountability. Without a quantitative scientific assessment of the herd, the PGC has no solid evidence as to whether the herd is prospering, stable, or collapsing.
I thank Mr. Feaser for explaining my point in his quote in paragraph 15, where he states, "Mr. Eveland later contradicts his own statement when he accurately quotes from the Game Commission deer plan, "Deer Management objectives are no longer defined by deer densities"." Deer management objectives should be defined by deer densities and other quantitative population values, Mr. Feaser, and it is inconceivable that they are not.
Incidentally, an overwinter deer population of 1.27 million (as would be required to provide a stable harvest of 316,240 deer per year) would yield a density of 48 deer per square mile on every square mile of forested land in the state, or 36 deer per square mile on every square mile of forest, woodlot, pasture, and cultivated and uncultivated agricultural land in the state.
Following spring births and the calculated growth of the population to 1.7 million deer, 51 deer would be required on every square mile of forest and agricultural land in the state. I urge the PGC and Mr. Feaser to choose whichever density with which they would feel most comfortable – 36, 48, or 51 deer per square mile – and then try to convince sportsmen that there are that many deer on every square mile of habitable land in the Commonwealth, because that is how many deer would be required to permit an annual harvest of 316,240 deer.
If the PGC cannot justify 36-51 deer per square mile, then their harvest estimate of 316,240 deer in 2010, and their repeated harvest estimates averaging 333,338 deer per year for the past six years, must be inaccurate. If their estimates are inaccurate, then there are two possibilities: either their estimate is the result of incompetence or deception. If, perchance, their harvest estimate is correct, then, I repeat, a dire circumstance exists, because there are not 1.7 million or even 1.2 million deer in Penns Woods that are available to keep producing this high-estimated harvest for an extended number of years. If this were the case, then the herd would be collapsing.
The PGC questioned the accuracy regarding my claim that the agency has a target of five to six deer per square mile in Wildlife Management Unit 2G – stating that , "In fact, there are no deer density targets in the Game Commission's 2009-2018 deer management plan..."
During personal communication with PGC Commissioner David Putnam, he informed me that a target of 5-6 deer per square mile was intended for WMU 2G, and that in some areas of 2G the herd may have been reduced to only 1-2 deer per square mile. I would ask that Mr. Feaser place this complaint with Commissioner Putnam instead of with me.
I agree with Mr. Feaser that the PGC does not use target densities in any of the state's 22 WMUs. Therein lies the problem. The PGC's unscientific, subjective, value-laden, impact based, fly-by-the-seat-of-your-pants approach to manage deer is an embarrassment for the Commonwealth and a threat to the future of sport hunting.
In conclusion, the PGC states, "Mr. Eveland's finger-pointing, erroneous calculations, and inaccurate reporting mislead the public. None of his claims promote a constructive discussion on deer management, nor do they do anything to improve deer management for Pennsylvania's citizens, wildlife or habitats."
To this I respond by levying the same charge against the PGC: their actions do nothing to improve deer management. In fact, to the contrary! It is estimated by professional biologists as well as PGC staff that the herd has been reduced by over 50% in most areas of the state, and to as much as 85% and more in some areas. During a conversation with a PGC deer biologist and staff associate, it was proudly stated that "We've literally exterminated deer in some areas, and regeneration still hasn't returned."
Such attitudes and actions are unconscionable, and represent a total disregard for sportsmen and the game animals for which the PGC is charged with managing. It is high time that elected officials and decision-makers realize the severe shortcomings of this agency, and correct the problem.
Regarding a decline in the number of license sales from 1.2 million to last year's low of about 670,000, a PGC long-term professional insider has repeatedly assured me that general license sales have declined to this point, and that the PGC has been masking this low number by including all forms of multiple license sales in their press releases.
• "Pennsylvania's State Forests have received Green Certification as a Sustainable Forest. When that happened four years ago, a great deal was made of it. The Governor accepted the certification with fanfare amid a blizzard of news releases."
• "There was one complication. The team that inspected the forests, monitored the Bureau of Forestry, and ultimately recommended Green Certification pinpointed a major problem: the adverse impact of deer on the forest."
• "Something had to be done quickly or the next review might not be so favorable. In fact, Green Certification might be withdrawn and that would be an embarrassment to the current administration and its Department of Conservation and Natural Resources. Calling it politically damaging would be an understatement."
• "It was no coincidence that a major effort to overhaul Pennsylvania's deer management program followed."
• "There were, of course, close ties between the Governor's Office and the Game Commission. Even the composition of the Board of Commissioners favored the party in power. As astronomers like to say, all the stars were in alignment. The time was right. This is the reality of political pressure in resource management."
• "Chances are you'll never hear any of this mentioned at a public meeting where deer management is the subject. Yet it's there, just as certainly as spring follows winter."
that "The bottom line is Mr. Eveland's allegations that the Game Commission's deer program was designed by some secret cabal are false", my answers to Mr. Feaser and the PGC in the above two points should be sufficient to answer this claim. Nevertheless, I will, herein, provide additional documentation toward this end.
• "Furthermore, we recognize that the BOF has no regulatory authority over the deer resource on its own lands. Yet, the unnaturally high levels of deer herbivory in these Districts is not a random, uncontrollable event like an insect outbreak – it is a deliberate consequence of the deer management program administered by another state agency, the PA Game Commission. Thus, the ultimate stewards of this public resource, as well as the major benefactors of certification – the Commonwealth of Pennsylvania – have unintentionally created conflicting policies relative to sustainable forestry over which the BOF staff (the designated caretaker of these public resources) has only limited control."
• "The BOF's certification is therefore conditioned on the eventual resolution of this important matter."
• The team leader was Bryon P. Shissler..."
• This process began in December 1996..."
• "...BOF updating its 15-year management plan to be implemented in the year 2000."