DEP Commissioner Lisa Jackson
Trenton, NJ 08625
By fax: 609.292.7695
5 January 2007
Re: Net-and-bolt deer control proposals in Millburn and throughout New Jersey
To the Commissioner, and for the public record:
As a national advocacy group with experience in animal-protection and environmental matters since 1957, writing on behalf of our membership in all states, including more than 10 thousand New Jersey residents, we submit the following comments in support of an immediate ban on net-and-bolt deer control in Millburn and throughout New Jersey, under the statutory authority granted to the Commissioner.
“Net and bolt” refers to a practice of luring deer to bait sites under suspended nets. The nets are then dropped on top of the deer, typically capturing several animals at a time. The killers then converge on the netted deer, trying to physically control and restrain them in order to press a captive-bolt gun against their heads and firing a retractable steel rod into their brains. Incidents occur in which the deer struggle and kick, sometimes fracturing limbs or sustaining other injuries. Deer who move as the bolt is fired can be painfully wounded, not killed, and the struggle continues until additional shots are fired.
White Buffalo, a commercial operator which has been hired to employ this method in New Jersey communities, acknowledges: “Deer are subjected to great amounts of stress during the restraint component.” Stress may be so acute as to cause the death of some of the deer prior to bolting.
We’re dismayed that the New Jersey Fish and Game Council would consider such activities, let alone approve them. New Jersey law prohibits “the unnecessary infliction of cruelty, abuse or harm upon animals.” Exemptions could be sought in endless scenarios, but that does not mean they ought to be.
Purported justifications -- and sane responses
Burgeoning population of deer has been cited as a problem in New Jersey. We have reviewed the practice of netting and bolting deer as a method of deer population management and have concluded that this method is unsound and unacceptable. As deer communities grow, there is less food and leafy, sheltered habitat available for each deer. Numerous studies over the years have shown that both the reproductive rate and the survival rate of deer will then decrease. Thus, a natural balance.
On the other hand, when a vacuum is created (e.g., by hunting or through violent population management) and food sources or other conditions that attract deer remain, new deer are likely to quickly repopulate the area. Thus, killing is cyclical.
Landscape damage has been cited as a justification for using net-and-bolt control. We suggest that communities pursue peaceable means of dealing effectively with deer over the long term, such as limiting development and suburban sprawl as well as planning “green routes” for wildlife when construction does go forward, planting deer-resistant vegetation, and using properly designed fencing. Suitably tall fencing, either manufactured polyethylene mesh or natural, such as high bushes, offers the most effective way to eliminate deer browsing.
Road accidents (involving somewhere around two dozen incidents a year in Millburn) have also been cited. To the extent that killing stimulates movement in the short term, and encourages deer reproduction over the long term, it’s illogical to maintain that killing deer will result in fewer car collisions. The best way to avoid such accidents is to properly maintain roadway reflectors, enforce speed limits, and encourage the use of public transportation. Driver-education and advertising campaigns can also teach basic precautions to avoid accidents.
In 2002, Friends of Animals surveyed incidents in which drivers hit deer. The Missouri Insurance Information Service, the Erie Insurance Group, and the State Farm Insurance company all observed that accidents were exacerbated by human violence against deer.
In summary, net-and-bolt deer control is unreasonable, ineffective, and grotesque, and we urge its immediate prohibition.
Please contact Priscilla Feral, president of Friends of Animals, at 203.656.1522 if you would wish to discuss this further.
Friends of Animals