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Official Comments from FoA and CARE on Deer Control in Valley Forge Park

SUBJECT: Deer Management

DATE SUBMITTED: 11 February 2009

Comment for the official record, on the draft White-Tailed Deer Management Plan/Environmental Impact Statement for Valley Forge National Historical Park

To Ken Salazar, U.S. Secretary of the Interior; Kristina Heister, Director of Natural Resources, Valley Forge National Historical Park:

Just a few minutes to the west of Philadelphia, Valley Forge National Historical Park, a five-mile area spanning northeastern Chester County and southwestern Montgomery County, once temporarily housed George Washington. Since then, it has been valued mainly for historical reasons, and much of the site’s vegetation was pulled out and modified for that purpose.1 Its historical purpose, combined with its small size and heavy traffic, means it will never be a full and pristine biocommunity. It's been part of the national park system for the last three decades; and in the past few years, in the midst of some area residents complaining about the park’s concentration of deer, or that their personal ornamental plants have been eaten by deer,2 the interest in killing the deer has arisen.

In January 2009, as a local resident and as a representative of Friends of Animals, a non-profit advocacy organization founded in 1957, I (Lee Hall) attended the public comment meeting at Valley Forge Park, presented by national parks officials with collaboration by the Pennsylvania Game Commission.3 The purpose of the White-tailed Deer Management Plan and Environmental Impact Statement (“Plan/EIS”), according to the documents presented at the meeting and to the general public, is to develop a deer management strategy that supports long-term protection, preservation, and restoration of native vegetation and other natural and cultural resources. Specifically cited as a basis for proposed action is "unacceptable" damage to the understory of the woods and a laundry list of other perceived problems, including the threat of Chronic Wasting Disease, which has not been recorded anywhere in Pennsylvania.4

With a few dozen other area residents, I watched the slide presentation geared to persuade area residents to accept “Alternative D”: agents from the US Department of Agriculture in the park, with rifles and silencers, and orders to kill the vast majority of the park’s deer (about 80%), beginning in winter 2009-10, and continuing the same way for at least four years. What I witnessed was a promotional campaign to convince area residents to accept four winters of shooting in a national park that’s close to their homes, jeopardizing their safety and peace of mind. Alternative D would then spend future years controlling the deer with birth control -- most likely leuprolide, a hormone-based formula.

The natural reduction and stabilization of this deer population since 2005 challenges the key premise of the Plan/EIS -- that the numbers of deer living in this community need to be reduced. Of course, v egetation is a vital part of any flourishing ecology, and the government is correct to protect it in parks -- although the mission of Valley Forge Park puts emphasis on historical value and the Park is highly built, which indicates many factors affecting plant health that, unlike deer, have no natural symbiosis with this ecology. Deer have always eaten native plants, plants that naturally regenerate. Moreover, throughout the public NEPA presentation at the Park on 15 January 2009, absent was any statement by Park officials recognizing that the dignity of a conscious being must, ethically, be weighed differently from the value given to other entities that are not conscious -- that deer need special concern in decisions involving the ecological balance of a space. Ethically speaking, conscious beings aren’t just a factor to erase to solve a perceived problem.

Valley Forge Park is largely unfenced, and is known as a place where deer seek shelter and a peaceful life. Routes 23 and 252 run traffic through the middle of the Park, however, and the Plan/EIS notes that there have been deer hit by drivers. It’s common to see cars exceeding the speed limit. Simple steps (even bumps) to end speeding in and around the park would prevent accidents. Those of us who must use these roads, whether in daylight or the dark, can safely say the deer have been no factor for those of us who obey the speed limit.

The Pottstown Expressway also runs through the Park, and all these roads connect a suburban residential area to a network of interstate routes, and to King of Prussia Mall, one of the two largest shopping malls in the country. Planned expansion of the Penn Turnpike is a genuine threat to native vegetation with which deer are simply symbiotic -- yet that expansion is mentioned, but not critically questioned, in the Plan/EIS.5 Every time such construction occurs, there is less room for native plants. Where are the forward-thinking moves to work with state planners so that public transport can become more attractive to commuters and road-widening is avoided? The Plan/EIS touches on the importance of collaboration between Parks officials and local government to address this:

Another transportation corridor development being considered is improvements to the metro transit system . The R-6 Extension public transportation project is proposed for the Schuylkill Valley corridor, extending between Reading and Norristown . The region within the corridor is one of the fastest growing areas in southeastern Pennsylvania. Its two principal highways, the Schuylkill Expressway (1-76) and the US 422 Expressway, as well as many arterial and secondary roads, are plagued by congestion. With the tremendous growth of jobs and population taking place in the corridor, land development is occurring rapidly, with commensurate loss of farmland and open space. Meanwhile, many of the older, formerly industrial towns in the corridor desire economic development. Existing public transportation consists of limited bus service, concentrated primarily toward the Reading and Philadelphia ends of the corridor, and commuter rail service between Philadelphia and Norristown and Philadelphia and Paoli that do not directly serve the newer centers of growth in the corridor.6

Addressing these matters should be paramount. Killing the deer and managing them through some yet-undecided pharmaceutical means should not be done at all. Although decisions under NEPA cannot be based simply on seizing upon the apparently easiest answer, eliminating deer seems the quickest response to receiving complaints about them. But the Parks officials need to undertake what their own Plan/EIS logically instructs: diligent collaborations with appropriate parties regarding alternatives to reduce traffic pressure, such as expanding the schedule of the local SEPTA train, and offering more attractive bus services. Traffic directly impacts the atmosphere, the ozone, and the vegetation of the park; and its effects will be exacerbated by road construction plans.

Alternatives under consideration

The four alternative courses of action currently being reviewed to comply with federal law are:

Alternative A: No Action. No shooting, no introduction of contraceptive substances into the Park. Biologists will test for Chronic Wasting Disease as they do already: a deer dies, they test for it. This is the common-sense alternative, endorsed and urged by the members and supporters of Friends of Animals, and the signatories to this submission.

Careful use of fencing and green corridors would not offend such a resolution. Native deterrent plants and strategically positioned fences can, when put into place with care and diligence, be used respectfully. Collaborations with outside parties (e.g. the state government, Jenkins Arboretum, local landowners, volunteers to remove introduced vegetation) could also reduce the concentration of deer, ease traffic-related tensions, and collaborate in ensuring native plants and birds thrive in the region. And weeding by hand is the best way to remove problematic plant species.7

● Alternative B: Combined “non-lethal” actions (fencing and reproductive control). Recently added is: "Live test and cull CWD-positive deer." There is no need to test and kill live deer. Reproductive control is inappropriate for free-roaming animals living in nature. Deer have natural modes of controlling their numbers.

● Alternative C: Combined lethal actions, i.e. “sharpshooting and capture and euthanasia.” Deploying sharpshooters against deer is inappropriate. Referring to systematic killing to control a population as "euthanasia" is inappropriate. The addition of "active lethal surveillance for CWD" is also inappropriate. As reported by the Pennsylvania Game Commission and by Kristina Heister, Natural Resource Manager at Valley Forge Park, Chronic Wasting Disease has not been detected in Pennsylvania; nor is it known to be transmissible.8 Killing deer within Pennsylvania will thus have no effect on CWD in the state.

● Alternative D (National Park Service preferred alternative): Combined lethal and “non-lethal” actions, i.e., “sharpshooting and reproductive control.” Recently added to this alternative is “active lethal surveillance for CWD.” Alternative D is misguided in every aspect. Valley Forge National Historical Park should n ot deploy sharpshooters against deer, nor kill them, nor contrive or exaggerate reasons to fear them, nor trap them and impose contraceptives on them.

Killing deer by the hundreds will not protect local gardeners’ azaleas from disoriented deer looking for a safe spot to eat. Nor will it stop cars from crashing into deer in icy midwinter. If the park's plan were to be accepted, frightened deer will inevitably scatter, in attempts to avoid the danger posed by sharpshooters. The scene is not entirely safe for humans either, as rifle bullets can travel three miles .9 After hundreds die and are dragged out of the park, the deer, following their nature, will rebound with extra fawns in spring; flowers will be eaten and flowers will return. It is hardly natural to destroy deer or other animals -- who, officials might need to be reminded, didn’t turn Valley Forge woodlands into parking lots -- for eating the plants that sustain them.

Within the public comment process, a biologist presented audiences the opportunity to decide their views while listening to information to sway them to agree with the preferred alternative. If the choice falls in line with what is expected by the Parks officials and the state Game Commission, there may be distraught letters, but a sense of normalcy is to be maintained; and people are expected to grow accustomed to the idea of people entering the area with rifles, and that deer must be killed.10 It is important not to let use a result-oriented comment process shut out, and stamp out, more peaceable and sensible views.

Fertility control unacceptable

Currently, no contraceptive has been formally approved by the Food and Drug Administration for use on free-living animals in the United States; various contraceptives have, however, been tested on deer, and proponents of this form of control call it an effective way to alter sexual activity and reproductive patterns of deer. For years, the development of this concept has involved experiments with porcine zona pellucida11 and gonadotropin-releasing hormone on captive white-tailed deer at Pennsylvania State University. In the male deer, results included “immunological castration, compromised libido and abnormal antler development.”12 Abscesses, inflammation, pain, reduced fat content in bone marrow are some of the side effects observed in other studies.13

Controlling the fertility of free-ranging animals is physically intrusive and can alter the social structure of the entire group.14 It is also misguided. It prevents future generations from appearing in targeted areas, even as our own species spreads out ever further with our roads, malls, and mansions.

As of 15 January 2009, the Sierra Club of Pennsylvania is siding with the Game Commission for Alternative D - contraceptives as well as lethal actions in Valley Forge Park. It’s illogical that local environmentalists would adamantly promote the reduction of deer population in the name of saving birds, yet have little to say about the introduction of contraceptive substances into the environment and into the natural food web. Moreover, to use the park’s deer experimentally (at the time the alternatives were issued, and at the time of this writing, fertility control can only be considered experimental) makes no sense. Experimental fertility control has prolonged the six-year lifespans of the Assateague Island mares to 20 years due to eliminating the biological stress of reproduction. To artificially prolong animals' lives does not reduce their numbers and thus it contradicts the Valley Forge biologists' stated preference. There are natural alternatives, although they would take patience -- a quality that’s sorely needed at Valley Forge.

 Park ecology

 On several ecological points, we agree with Kristina Heister, the Park’s Director of Natural Resources, who explained having rejected an idea to import wolves -- rightly so. Wolves cannot be expected to restrict themselves within the boundaries of a five-mile park next to the largest shopping mall on the east coast of the United States. Nor should they be moved away from established communities of wolves to do so. Kristina Heister and the park officials are also correct to reject any proposals to relocate the deer to private properties. Attempts to relocate the deer would be physiologically dangerous, socially disruptive, and unacceptable.

There are, however, alternatives that would not require violent or invasive actions. Although we support the “no-action” alternative, the idea that the public must choose deer control or nothing is a false dilemma. Coyotes are beginning to re-establish themselves in the area. Should these natural predators gain a presence in the Park, they will remove some of the young, and also the sick, and thus check the deer numbers while promoting health in the deer. Unlike larger predators, coyotes could do well in the range Valley Forge Park provides.

The EIS in fact acknowledges that animals of some species to whom deer are a food source, including foxes and coyotes, could benefit from high deer density and open understory conditions.15 Other animals, such as box turtles, vultures, crows, and chickadees, may also eat deer carcasses.16 Small predators, such as foxes, hawks, owls, and skunks may also benefit from a more open understory, as prey would be easier to find. 17

The coyote population will, of course, take time to rebound, but this means we should promote their role in the ecosystem of our region. These predators, rather than be considered vermin by local residents, must be encouraged to prosper and to keep the ecological balance intact. The park administrators could and should diligently publish information to promote safety and respect for coyotes.

Concern about the health of native plants as integral to this biocommunity is laudable. But the Park does not exist in a vacuum, and its officials should not be acting as though they do. The Jenkins Arboretum, a 46-acre space specifically intended as a wildlife sanctuary18 that provides a habitat for many varieties of wildlife, such as green herons, foxes, king fishers, red-tail hawks, owls, flying squirrels, turtles, and 108 identified bird species (yet fenced against deer), is just across from Valley Forge Park, on the south side of Route 202. According to its website: “The Arboretum is one of Pennsylvania's major horticultural showcases of native trees, shrubs, rhododendrons, azaleas, laurels, blueberries, ferns and wildflowers. Included in the collection are rhododendron varieties from all over the world.” Have its administrators been approached about shifting to a complete emphasis on native plants, or arranging ways to allow deer more acreage to roam? Have land owners (especially those with wooded lands) and landscapers in the area been approached regarding the importance of using native plants wherever this is appropriate? These are merely examples of the kind of thinking necessary for keeping as much ecological integrity as possible in suburban areas. Parks officials ought to be encouraging respect for the other animals whose habitat in this area is so quickly diminishing. That Parks officials are actually encouraging local residents to believe that free-roaming animals are too numerous, that they have no business on the land the minute they do something inconvenient (even including the ingestion of ornamental plants), and the answer is to eliminate them -- this is the opposite of responsible leadership.

A fundamental change in circumstances

“Deer management strategies are adaptive and dynamic,” states the plan, “allowing for the incorporation of new scientific information over time that may modify management methods to best meet objectives in taking action.”19

Important new scientific information has already appeared. In January 2009, a study was published in Proceedings of the National Academy of Sciences that made headlines worldwide.20Newsweek noted how the study challenged the entire premise on which hunting, animal commerce, and federal animal-control policies rest. Theodore Roosevelt -- naturalist John Muir's staunchest political ally -- stalked deer, pronghorn antelope, bighorn sheep and elk; in a single century, explains Newsweek, “many of the kind of animals Roosevelt routinely killed are becoming rare.”21 Hunters, poachers, and commercial traders have thrown evolution into reverse by whittling away those who would otherwise be the best-equipped survivors.22 Social interactions are showing adaptations as well.

The more highly controlled the environment, the lower the genetic diversity.23 These changes make no evolutionary sense and ultimately threaten the viability of a species.24

The idea that target species evolve in response to predation is not new, but t he results of study by Chris T. Darimont et al, “ Human Predators Outpace Other Agents of Trait Change in the Wild,” encompasses research in the U.S. and Canada taking in decades of observation, and provides new scientific information in a field in which “a comparison of the rate at which phenotypic changes in exploited taxa occurs relative to other systems has never been undertaken.”25 It also explains why this study is of vital importance to a change in the way humans think about managing other animals. Its ramifications will challenge not just on the level of how we should manage them (it describes, for example, the deleterious effects of hunting and the commercial fish trade on evolution), but that we think we can and should manage them in the first place. The authors state that the study is “providing a new appreciation for how fast phenotypes are capable of changing” and that animals targeted by humans “show some of the most abrupt trait changes ever observed in wild populations,” and adds: “Specifically, the widespread potential for transitively rapid and large effects on size- or life history-mediated ecological dynamics might imperil populations, industries, and ecosystems.”

The study focuses on hunting and commerce, but will clearly be relevant to the problems resulting from human management and control generally. Distinct parallels are visible in the effects of imposing contraceptive management on free-roaming deer. Recent contraceptive research on deer has resulted in such effects as “immunological castration, compromised libido and abnormal antler development.”26 Any contraceptives will have some effect on the social interactions and physiology of deer; that is the point. And yet the introduction of pharmaceutical control of some kind is part of the “Alternative D” which the officials at Valley Forge Park would have the public accept as part of a viable plan to manage deer.

This study in Proceedings of the National Academy of Sciences is a red flag, a warning against accepting the management and control framework through which Alternatives B, C, and D were conceived. Shooting large or active deer, or at large numbers of a given population, and compromising their social and reproductive interactions -- all of which are components of the Valley Forge proposed actions -- comprise an affront not only to the ecology of the park and to the dignity of conscious animals within it, but also to evolutionary principles. Alternative A -- no action against deer -- is the only reasonable option; in the greater context, the overall impact of all others would be long-term, major, and adverse. Now, a major study that indicates this in clearer terms than previously understood. The process is thus faced with a fundamental change in circumstance and Alternatives B, C, and D must be taken off the table.


T he deer population tends to rise in concentrated areas due to gardening practices, construction, and an absence of natural predators. Human factors that can be altered must be given attention, or the calls of “too many deer” and the pressure to destroy them when they are deemed inconvenient will be cyclical . Environmental degradation to the park has taken place over many years and is also impacted by previous, deliberate removals of natural vegetation, by vehicle exhaust, construction, and millions of tourists.  The government’s proposal is not an environmental fix so much as a plan of convenience, demonstrating a poverty of innovation needed to advance ecologically respectful policy. Killing deer is not the answer to the decline of plant life in a sprawling, concrete-covered suburb. 

We must diligently work to foster respect for carnivorous and omnivorous animals where they survive, and keep the biocommunity in the balance it evolved to maintain. And where we’ve made mistakes, we should resolve not to condone still worse ones. Alternative A, no action against these deer, is the right thing to promote. No shooting and no pharmaceutical control. The "too many of them" claim everywhere paves the way for the domination and control of free-roaming animals - first predators, then the prey. It’s extremely disingenuous to kill and foist lab-created fertility control vaccines on members of the natural community and claim to save that community as a whole.

The plan, including the preference for shooting and birth control, was outlined by a biologist. We’re expected to defer. Yet their plan isn’t right, natural, or needed. It doesn’t uphold cultural values or environmental awareness. It’s eerie on every level. Local, state, and national decision-makers should press for answers that genuinely respect the autonomy and dignity of the deer, and the health of the ecology.

Friends of Animals and all the signatories to this statement strongly support “Alternative A: no action” on the deer in Valley Forge National Historical Park.

Very truly yours,

Lee Hall Legal director, Friends of Animals

This submission is endorsed by CARE ( Delaware Valley non-profit advocating “Concern for Animals, Respect for the Environment”).

  • 1. For details of the history of the park’s landscaping and ornamental plantings see Draft White-tailed Deer Management Plan/Environmental Impact Statement (hereinafter Plan/EIS), Chapter 1, Purpose of and Need for Action, at 7-8.
  • 2. Ibid., at 32, stating: NEPA requires that economic and social impacts be analyzed in an EIS when they are interrelated with natural or physical impacts. Economic impact would potentially result from deer browsing damage to crops and landscaping on private lands adjacent to the park as a result of changes in deer populations at Valley Forge NHP…The presence of deer on neighboring properties has been linked to loss and damage of ornamental vegetation.
  • 3. Public meeting at Valley Forge Park (15 Jan. 2009), led by Kristina Heister, held to discuss and solicit input on the draft plan.
  • 4. “ The purpose of the plan/EIS at Valley Forge NHP is to develop a deer management strategy that supports protection, preservation, and restoration of native vegetation and other natural and cultural resources throughout and beyond the life of this plan/EIS. The purpose of the plan/EIS also is to provide appropriate response to CWD at Valley Forge NHP.” Plan/EIS, Chapter 1, Purpose of and Need for Action, at p. 1. CWD is thus cited as one of the plan’s chief purposes although there is no CWD at Valley Forge Park.
  • 5. Plan/EIS, Chapter 4, Environmental Consequences, at p. 4.
  • 6. Ibid.
  • 7. See Norman A. Bourg, “Interactive Effect s of White-tailed Deer and Invasive Plants on Temperate Deciduous Forest Native Plant Communities” in t he 93rd ESA Annual Meeting (Ecological Society of America; Aug. 2008) (stating “Deer management, such as fenced exclusion or population reduction, in the absence of invasive plant removal, may therefore be insufficient to promote restoration of the native plant community.”). Available: (visited 11 Feb 2009).
  • 8. ublic meeting at Valley Forge Park (note 3 above).
  • 9. See Ted Sullivan, “Deer Hunting With Rifles Creates Safety Debate,” The Janesville [ Wisconsin] Gazette (11 Sep. 2008).
  • 10. The Game Commission receives revenue through the licensing of hunting, and is thus at an advantage when deer populations in the state are high. Because deer will always be pressed into green spaces such as Valley Forge, it is likely that the current plan is paving the way for a yearly shooting cycle.
  • 11. The contraceptive vaccine porcine zona pellucida, derived from the ovaries of pigs, is used to control the ponies who roam the Assateague and Chincoteague Islands. Dogs, rabbits, and marmosets, are used in zona pellucida studies; ovarian abnormalities in all of these animals have been produced in labs. See, e.g., W.H. Wheir et al., “Immuno-Sterilization in Dogs Using Zona Pellucida (Zp)-Based Vaccine,” in Allen T. Rutberg (ed.), The Role of Immunocontraception (published in 2005 through Humane Society Press).
  • 12. Gary J. Killian and Lowell A. Miller, “Behavioral Observations and Physiological Implications for White-Tailed Deer Treated With Two Different Immunocontraceptives” (2001); available: (visited 9 Feb. 2009) . Research on deer contraceptives continues nationwide. See Maryland Department of Natural Resources, “Deer Management Options” (undated) (visited 2 Jan. 2009).
  • 13. Paul D. Curtis et al., “Pathophysiology of White-tailed Deer Vaccinated With Porcine Zona Pellucida Immunocontraceptive,” Vaccine (Vol. 25, 11 April 2007); at pages 4623–4630 (available: (visited 9 Feb. 2009).
  • 14. “Behavioral Observations and Physiological Implications for White-Tailed Deer Treated With Two Different Immunocontraceptives” (note 12 above).
  • 15. Plan/EIS, Chapter 4, Environmental Consequences, at p. 41.
  • 16. Plan/EIS, Chapter 4, Environmental Consequences, at p. 41.
  • 17. Plan/EIS, Chapter 4, Environmental Consequences, at p. 41.
  • 18. See “ Early History of the Arboretum”; available: (visited 8 Feb. 2009).
  • 19. Chapter 1, Purpose of and Need for Action, at p. 1.
  • 20. See, e.g., Cornelia Dean, “ Research Ties Human Acts to Harmful Rates of Species Evolution,” New York Times (12 Jan. 2009); available: For related information see Lily Huang, “I t’s Survival of the Weak and Scrawny: Researchers see 'evolution in reverse' as hunters kill off prized animals with the biggest antlers and pelts,” Newsweek (magazine issue dated 12 Jan. 2009); available: or in a one-page, printable format at References visited 9 Feb. 2009.
  • 21. “I t’s Survival of the Weak and Scrawny,” ibid.
  • 22. Ibid.
  • 23. Ibid.
  • 24. Ibid.
  • 25. Chris T. Darimont et al, “ Human Predators Outpace Other Agents of Trait Change in the Wild,” Proceedings of the National Academy of Sciences (12 Jan. 2009). Edited by Gretchen C. Daily, Stanford University. Abstract and link to full text: (visited 9 Feb. 2009).
  • 26. “Behavioral Observations and Physiological Implications for White-Tailed Deer Treated With Two Different Immunocontraceptives” (note 14 above).