December 3, 2001

To: Dan Rosenblatt, Ph.D.
Regional Wildlife Manager, N.Y.S. D.E.C.,
Division of Fish, Wildlife and Marine Resource, Bureau of Wildlife
SUNY Bldg, 40
Stony Brook, NY 11790-2345

The Fund for Animals, on behalf of its 200,000 members, submits the following comments regarding DEC's proposed regulatory changes which would expand the January special firearms arms deer season deer season to the end of the month.  We request that these changes not be adopted due to the following serious public safety consequences and lack of effectiveness of hunting to solve deer- people conflicts.

1. While DEC's cover letter attempts to justify the extension of deer killing in order to decrease deer /vehicle accidents, the reality of deer hunting is that it increases the
number of motor vehicle accidents. Data from insurance industry study findings report that the first day of deer hunting season shows a dramatic and tragic five-fold increase of deer/ motor vehicle accidents. Deer frightened by bullets and arrows run blindly into the roads. These are not truly accidents since they are foreseeable and therefore avoidable. It is therefore illogical and dangerous to public safety to add more days to the deer season. Playing Russian Roulette with people's lives in order to provide recreational hunting opportunities is clearly unethical . Property damage and resultant financial loss is tremendous and places a strain on individuals and insurance companies. But the most nightmarish consequences of hunting and motorist collisions are the human deaths and injuries. How can one justify the physical and emotional pain suffered by the motorists and their loved ones?

2. While temporarily reducing deer numbers, hunting actually increases the deer population. Killing deer promotes an increase in fawn births in the spring since surviving pregnant female deer who have more available food produce twins rather than single births. The Richter and Labisky study revealed that the incidence of twinning was 38% on a hunted site compared to 14% on a non-hunted site. It also creates a higher prevalence of pregnancy in yearlings. In other words, after hunting season, deer have more young and breed at an earlier age. The result is a rebound effect in population size. The DEC's promotion of hunting deliberately supplies continuous living targets for recreational hunting. This policy provides a funding stream of license fees and federal monies which not only ignores public safety but endangers public safety.

According to DEC literature, in order to reduce the deer population, over 40 % of does must be killed. Killing 40% of female deer simply stabilizes the deer numbers. (Hunting and Trapping Regulations Guide 1995-96, NYS DEC). This proposed
regulation does not limit the killing of deer to females only in order to achieve such a
large percentage of  kills. Recreational hunts tend to remove less than 40% of the entire deer population including male deer. It appears that DEC would rather maintain a fruitful and continuous supply of deer herds to be hunted as a recreational opportunity rather than seriously address the abundance of deer.

3. DEC promotes the myth that recreational hunting solves an assorted array of problems. Instead, the focus needs to be targeted solely on truly effective and non-lethal
methods, which have proven to save human and deer lives such as Strieter-Lites, These reflectors, used on segments of roadways. have reduced deer vehicle collisions by as much as 100% in communities around the nation. In New York State, the      Owego district in Tioga county has reported a 100% reduction on the reflector sites and the highway department servicing the village of Turin, New York in Lewis county found a reduction of 88% during the first year. The New Jersey Dept. of Transportation has officially approved the use of Strieter- Lites. The devices reflect light from a vehicles headlights and prevent deer and other wildlife from entering the road until the vehicle has passed. It is easily installed and the system is economical, costing approximately $3,600 for 200 reflectors per mile. ( Reflectors are placed on specific, known collision road sites-not the entire length of the road). Consider the following - according to the National Safety Council the average cost of a car accident resulting in one death was $980,000, for a disabling injury per person - $35,000 and property damage- $6, 400.  The Strieter-Lite company may be reached at (309)794-9800 or  www.strieter-kite.com.

Property damage by deer may be handled by non-violent means too, since killing some deer gives the survivors in neighboring areas an opportunity to enter the newly available habitat. Landscaping by homeowners should focus upon the purchase of
deer resistant plants which deer find distasteful or will eat only during very dire
circumstances (resource: Deer Resistant Nursery at (800) 595-3650 or
www.eerxlandscape.com). to protect vegetables and orchards , electric and non-electric fences may also be utilized ( see enclosed literature for detailed information).

4. Another concern noted by DEC is the "threat " of Lyme disease.  However, reduction of deer herds will not reduce Lyme disease since deer are not the only hosts for the tick which transmits Lyme disease. In fact, the nickname "deertick" is misleading , the Black-Legged tick (Ixodes Scapularis), are carried on a variety of species. The tick also parasitizes a wide range of avian and mammalian species including but not limited to 49 species of birds and all mammals except bats. According to the Northeast Deer Technical Committee's Annual Meeting Report , the white-footed mouse " is the most important host of the tick vector". . Researchers say that the younger nymphal ticks most responsible for transmitting the disease in its peak summer months are on mice and other small to midsized animals, not deer. It's the older adult ticks, which transmit fewer cases of Lyme disease, which feed on deer prior to dropping off to lay eggs.  Research by Jorge Benach (Chief Lyme Investigator for the NYS Health Dept. at Stony Brook 1987) suggest that deer removal " might result in ticks more aggressively seeking out humans since the tick prefers to feed on a progressively large host". This potential for a greater human safety risk to people when deer are reduced was again discussed in the Smithsonian text, " The Science of Overabundance: Deer Ecology and Population Management" in an article written by Wilson and Childs ( 1997), where it was pointed out that questing ticks (those seeking a bloodmeal) tend to be more prevalent when deer numbers are reduced.  There are several pivotal studies which show why hunting doesn't reduce Lyme Disease.

In a study of " The Effect of Deer Reduction on Abundance of Deer Tick", when as much as 70% of the deer present on Great Island ( Ma) were removed, there was
"no significant reduction of the tick". This begs the question of how a recreational hunt, which removes only 25%-30% , can reduce the abundance of tick when a
reduction of twice that does not! In addition, other studies showed that when deer
numbers are reduced, the ticks congregate in higher densities on the remaining deer
(Deblinger et al, 1993) or switch hosts ( Duffy et al. 1994, Mannelli et al 1993).

Most importantly, deer hunting seasons are poorly timed to affect tick reproduction, the ticks take a final blood meal and drop off deer in September to November prior to regular hunting seasons. The proposed hunt extension, which will occur at the end of
January, will be long after the ticks have already mated and dropped off the deer.  Thus the DEC's suggestion that this hunt will do anything to reduce Lyme disease is
completely misleading.

Computer modeling suggests that the Black-Legged tick population could be reduced to low levels in 3-5 years if 95% of the ticks could be reduced on 90% of the deer ( K. Stafford, 2001). One of the most promising ways to achieve this is illustrated through current experiments with the "4- Poster Feeder" which delivers an acaricide
called Amitraz to the neck of deer when they come through to feed on corn. This
kind of tick reduction could never be achieved through hunting and that's why Lyme disease researchers are not heard endorsing recreational hunting as a means of
controlling Lyme disease.

To learn about additional non-lethal options to help solve deer/people conflicts please
review the enclosed " Living With Deer" literature.

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