Josh First's Blog

Return of the Jedi: Hardcore Scientific Critique of John Eveland’s Fake Deer Management Ideas, His Jihad Against Wildlife Science, and His Epic Whining

June 30, 2018

Rebuttal by David S. deCalesta, Ph.D. to the Report by John Eveland titled:

“The Pennsylvania Game Commission’s Collapse of the Deer Herd, Mismanagement of Habitat and Wildlife Resources, Resulting Impacts to Rural Communities and the Commonwealth, and Violations of Title 34 State Law and The Pennsylvania Constitution”

Executive Summary

The Pennsylvania Game Commission’s management of deer and other wildlife species has been wrongly characterized by John Eveland as mismanagement of habitat and wildlife resources, responsible for the collapse of the deer herd, and in violation of Pennsylvania state law and the Pennsylvania Constitution. The report makes assertions concerning deer and other wildlife resources that are not supported by documentation or established fact, misstates the intent and purpose of Title 34 of Pennsylvania State Law and portions of the Pennsylvania Constitution, incorrectly states that deer management for Maximum Sustained Yield (MSY) is beneficial to deer and other wildlife resources, and makes statements about forest certification and deer management that are false and misleading. The recommendations he made in his report, if implemented, would revert Pennsylvania deer management to the period 100 years ago when deer were managed to satisfy the desires of deer hunters and ignored the advice and experience of deer professionals who predicted the dramatic collapse of the deer herd if it were not controlled. The gold standard for responsible management of natural resources is operating from a science-based model where methodologies proven by peer reviewed publications are implemented and improved upon with adaptive management. The alternative is managing based upon culture and tradition to appease the requests of a chosen and limited number of stakeholders irrespective of the wishes of, or impacts upon, other stakeholders who form a vast majority of Commonwealth citizens.  The Pennsylvania Game Commissioners must choose between promoting and implementing deer management that is either: 1) based on science for the benefit of all stakeholders affected by deer abundance; or, 2) based on culture and values of a minority of Pennsylvania’s citizens and which results in harm to the environment including wildlife habitat and wildlife species.

Preliminary Comments

The Pennsylvania Game Commission administrators face a momentous choice in deer management, by either: 1) incorporating the science of deer management as advocated by professional deer managers and regulating deer harvest, density, and impact for sustainability of all forest resources on the behalf of all Pennsylvania stakeholders; or, 2) regulating deer harvest to satisfy the demands of those deer hunters who want management to produce the maximum number of deer for hunting. With the exception of its system of Gamelands (less than 10% of Pennsylvania forestlands), the Pennsylvania Game Commission does not manage deer – it regulates deer harvest in ways to affect management on forestlands where private and public managers actually manage habitats for deer and other wildlife and plant species. Regardless of which stakeholders the Pennsylvania commissioners and administrators favor, harvest regulations adopted by the Pennsylvania Game Commission affect deer density and impact on forestlands of others. These “others” (private forest landowners and stewards/managers of public forests such as state and federal forests) manage for a variety of forest resources, produce food and cover for deer, create and maintain access to their forests that hunters use, and absorb the costs of browsing by deer on their forest resources. Hunters reap the benefits of the efforts of landowners to maintain habitat and access without sharing the affiliated costs borne by forest landowners and stewards.

The words of Aldo Leopold¹, the “father of wildlife management in America” written in 1943 chronicle what occurred beginning 100 years ago in Pennsylvania when the desires of hunters for more deer took precedence over the warnings and advice of professional deer managers.

“The Pennsylvania deer dwindled steadily from Revolutionary times until about 1905, when it was nearing extinction. In that year the first refuge was established. In 1907 a buck law was passed. By 1922, 30 refuges were in operation, and the annual kill of deer had increased in fifteen years from 200 to 6115. The herd in 1922 stood at about 400,000.

Joseph Kalbfus predicted as early as 1917 that the deer herd would someday get out of hand. He recommended a doe season every fifth year, but his advice went unheeded. In 1923 the Commissioned opened a limited local doe season, but sportsmen killed it by “boycott.” Their slogan was “Don’t be yellow and kill a doe.”

Local doe seasons were tried out in 1925 and 1926. In 1927, by which time the herd stood at 1,000,000, a statewide doe season was proclaimed by the Commission, but the sportsmen “marched on Harrisburg” and forced a rescinding order. In 1928 an antlerless season was finally put into effect. That this action was too long delayed is indicated by the wholesale starvation of fawns during the two ensuing winters.

In 1931, the Pennsylvania herd was estimated at 800,000 and the carrying capacity of the range at 250,000. In other words, even after the Pennsylvania herd had been reduced 20 percent, the range was still 220 percent overstocked.

Between 1931 and 1941 five antlerless deer seasons disposed of 448,000 does and fawns, but large-scale starvation, including adult deer, was still prevalent in 1938, when the herd had shrunk to 500,000. “Runting” by malnutrition was still widely prevalent. Equilibrium between the shrinking herd and its food plants was finally reached in 1940.

Deer damage to crops in Pennsylvania has been prevalent since 1915, and to forests and plantations since 1922. In 1938 “excess deer (had) in many regions resulted in the completed overthrow of natural forest regeneration, and made forest planting practically impossible.  Due to scarcity of food in the forests, wild deer were encroaching in hordes upon neighboring farms. Fencing one farm merely crowded the animals onto the neighbors’ farms. A special survey made in 1938 showed that half the deer range was producing less than fifty pounds per acre, which was virtual depletion.

The Pennsylvania herd now stands at about 500,000 or half the 1927 peak level. The reduction is the combined result of doe-removal, starvation, and range deterioration.

It is an open question whether the Pennsylvania history is not an example of “too little and too late.” A splendid success in deer management has been partially cancelled out by delayed public acquiescence in herd reduction.”

Today, the Pennsylvania Game Commission faces the same pressures as 100 years ago from hunters who want more deer, and all other stakeholders in Pennsylvania who want deer abundance to be in balance with nature and not causing them economic harm and creating health and safety issues.

The report by John Eveland represents a return to deer management of 100 years ago: ignoring or denigrating science in favor of a vocal segment of deer hunters who want to maximize deer abundance for hunting regardless of the negative impact on other Pennsylvanians.

As a professionally trained, experienced, and recognized deer researcher, manager, and consultant, I am compelled to speak out for science and the majority of Pennsylvanians who deserve better and informed deer management than that espoused by Mr. Eveland for the benefit of a minority of Pennsylvanians.

I also feel compelled to point out major discrepancies in the current philosophy of deer management—1) that public and private forest landowners/stewards who bear the costs of deer impact on forest resources, and who provide hunters with access to their lands and absorb the costs of providing and maintaining road access have little say in deer management on their lands, and, 2) that hunting regulations designed to optimize deer abundance take precedence over the impacts on these same public and private forestlands. It is true the Pennsylvania Game Commission designed and implemented a Deer Management Assistance Program to allow public and private landowners to attempt to [control] deer abundance and impact on forest resources under their care by issuing antlerless deer permits to reduce herd density, but it is also true that demands by hunters who want more deer to harvest have resulted in reductions in the DMAP program and concurrent buck/doe seasons designed to reduce deer abundance on the lands of those providing hunting opportunities and access for hunters.

It seems only fair that if the Pennsylvania Game Commissioners and administrators decide to regulate deer harvest to produce higher deer abundance in response to hunter demands, they should do so on lands the Commission actually manages – the system of state Gamelands.   Landowners and stewards of public and private forestlands, for which hunters and the Pennsylvania game Commission provide no financial assistance in deer management, and where sustainability and health of all forest products is a goal, should be permitted to control deer abundance with continued and enhanced programs like the Deer Management Assistance Program.

Regarding my rebuttal of John Eveland’s report:

First, my credibility as a rebutter is based on my career experiences and recognized expertise with deer research and management as presented at the end of this rebuttal. Secondly, I offer below the established model for determining truth and reliability of statements regarding management of natural resources based on science-established facts rather than on hearsay or personal perception (bias).

The science/research model for establishing truth and reliability of comments on deer management and the difference between these absolutes and culture and beliefs.

Management of physical factors, such as curing disease in medicine, sending a rocket to the moon, building an automobile, and providing clean and safe water to drink, is based on hard science as established by a strict system for conducting research. An hypothesis is formed, scientific studies are designed, data are collected and analyzed, and answers are determined by established criteria for testing hypothesis with statistics. There is no place for perceptions based on culture or values which cannot be tested for truth. When people are sick, they seek the services of doctors trained in science-based medicine. Astronauts only climb aboard space ships when they know the paths of these ships are established and controlled by physics. People only buy and drive cars they know have been developed and tested by engineers using science as their guides. People trust the purity of water out of taps in America because they know engineers and water purity experts have established through science how to purify water and keep it free of harmful chemicals. Management of deer should come under no less strict adherence to established science. If you wouldn’t trust your plumber to take out your appendix, or perform a root canal, why would you trust a person who yes, has been deer hunting for many years, but bases deer management on how many deer he sees in the woods and has no education or experience in deer management as a part of overall forest management? I may have watched years of episodes of ER but that doesn’t qualify me to make medical decisions on person’s lives.

The Rebuttal

My rebuttal is based on: 1) Mr. Eveland’s disregard for established science regarding deer density and impact and replacing science and facts with perceptions and beliefs of persons not trained in deer or forest ecology; 2) lack of facts, science or scientific publications presented to support his assertions; 3) inaccurate and misleading assertions about the Pennsylvania Game Commission violating state laws and the constitution regarding hunting and natural resource management; 4) favoring a single, minority stakeholder group (disgruntled hunters who want higher deer density) over the needs and desires of a majority of Pennsylvania citizens (including deer hunters who prefer quality to quantity in deer management) who are negatively affected by high deer density; and, 5) unsupported, conspiracy-theory type statements that denigrate, without proof, professional biologists from the Pennsylvania Game Commission, the Pennsylvania Bureau of Forestry, and outside professional agencies such as the Wildlife Management.

Disregard for Established Science

1. Eveland stated that, “For decades prior to 2000, the Pennsylvania Game Commission had used a ‘maximum-sustained-yield’ (MSY) method of game management to manage the state’s deer herd. According to this MSY method, herd size is maintained through a balance of art and science to provide the maximum number of deer on an annual basis for sport hunting while assuring the continued health of the forest ecosystem.”  He further claimed that, “(This) change in (deer management) philosophy began in 1998 at the request of DCNR by eliminating the traditional, scientific maximum sustained yield (MSY) method of deer management (that had made Pennsylvania one of the top two deer hunting states in the nation), and replacing it with a new, value-laden style called ecosystem management (that favored nongame species of birds and mammals, wildflowers, and native shrubs). Mr. Eveland incorrectly states that MSY assures the health of the forest ecosystem. Actually, scientists have demonstrated that managing a deer herd for MSY does exactly the opposite – the overabundant deer herd simplifies the structure and species composition of understory vegetation, negatively impacting wildlife habitat, herbaceous vegetation, and seedlings required to reforest a site after timber harvest².  The MSY philosophy (the concept of maximum sustained yield is a philosophy and not a management system) for deer management is based on the concept that at some optimum deer density the greatest number of fawns can be recruited by maintaining a maximum number of doe deer to produce a maximum harvest based on replacing the number of deer recruited annually by reproduction. However, such densities of deer are not sustainable nor are they good for understory vegetation and dependent wildlife species because deer at MSY severely and negatively impact forest resources^2,4. It is true that a new model of deer management based on ecosystem management which emphasizes sustained yield of all forest resources, including non-deer game and nongame species of birds and mammals, wildflowers, and native shrubs and trees is favored by Pennsylvania Game Commission and Bureau of Forestry. This new paradigm in forest/deer management (for sustainability of all forest resources) is desired by other stakeholder groups to whom the Pennsylvania Game Commission is just as accountable as it is to deer hunters who want maximum deer density.
2. Eveland states that, “ … in 2002 less than 4% of state forest stands were early-stage stands 0-15 years old, and by 2140 projections this percentage of early-stage forests remains the same. These young forests are vital for healthy wildlife populations including deer, grouse, about 150 species of other wildlife, and pollinators such as at-risk honey bees, bumble bees, and Monarch butterflies. DCNR’s old-growth policy will create increasingly devastating impacts to wildlife and the forest ecosystem as forests grow over the decades and centuries.” Mr. Eveland speaks out of ignorance, or disregard for established science that identifies old growth forests as providing key habitats for plant and animal communities, such as multi-canopied overstories, large snags as nesting sites, and high volumes of large fallen logs as critical wildlife and plant species habitat. Also, he disregards the fact that maturing forest stands cannot be harvested for timber (and creating early successional habitat) without first insuring that there is a diversity and minimum abundance of seedlings of a diverse group of trees present. Many forests in Pennsylvania, including BOF forests, have been so heavily overbrowsed by deer for so long that the only plants growing in the understory are ferns, grasses, exotic shrubs not browsed by deer, and a limited number of tree species (including beech an striped maple) that deer avoid browsing on. Harvesting trees from these sites guarantees that the resulting vegetation will be ferns and dense thickets of tree species of little value to deer or other wildlife species, not to mention being of zero future economic value as harvestable timber of desired species.

Lack of Factual Support for Assertions

1. On page one of his comments, Mr. Eveland cites a dramatic and permanent reduction of the statewide deer herd, a [purportedly resulting] devastating loss of hunters, and a multi-billion-dollar economic impact to rural communities, the outdoor industry, and the Commonwealth, but he provides zero numbers in support of his claim. It is true that the deer herd declined after the introduction of the three point antler requirement, concurrent buck and doe seasons, and DMAP program but Mr. Eveland provides no data in support of his claims. Furthermore, he provides no data to support his claim that the decline in deer abundance is permanent.
2. Eveland states that the “Pennsylvania Game Commission has ignored the creation of adequate habitat for deer, grouse, and an estimated 150 species of wildlife – placing Pennsylvania’s State Mammal, State Bird, and wildlife resources at risk – a violation of The Pennsylvania Constitution, Article I, Section 27.” Again there are no data provided to support this claim. Actually, science has shown that deer density exceeding 15 deer per square mile has a significant and negative impact on wildlife habitat, including herbaceous plants they utilize as forage, and on wildlife species (including deer)^5,6,7,8
3. Eveland makes the broad claim, “For decades, the Pennsylvania Game Commission’s conduct has represented a mix of hubris, incompetence, mismanagement, malfeasance, and outright violation of multiple state laws. The agency’s actions have been made with total disregard for its legislated mission and without regard for the egregious biological, social, and economic impacts that it has caused to the Commonwealth.”  However, he provides no supportive reference material, relegating his comments to the level of rant rather than reason.
4. Eveland states that, “The Pennsylvania Game Commission has taken the meaning of an autonomous agency way beyond its intended purpose and has corrupted its legislated mission by, instead, choosing to serve two special interests at the expense of wildlife resources and sport hunting.” He does not identify the two special interests, but he himself favors the deer hunter stakeholder group that wants higher deer density over the other stakeholder groups negatively impacted by overabundant deer (farmers, foresters, homeowners and their devastated landscaping, motorists and deer/vehicle collisions, hikers and other forest goers exposed to Lyme disease fostered by overabundant deer herds, birdwatchers seeking birds dependent on understory habitat devastated by deer, and hunters of other game species, such as grouse and turkeys whose understory habitat is decimated by overabundant deer).
5. Eveland asserts that, “the Pennsylvania game Commission has been accustomed to little oversight and accountability, which has fostered a culture of mismanagement and deceit. Except for law enforcement, the agency has arguably become more of a liability to the competent management of wildlife resources and sport hunting than a responsible steward of Pennsylvania’s natural resources.” Again, these comments are rant that he does not support with facts or reason. Actually, the Pennsylvania deer management program was reviewed positively in 2010 by wildlife professionals from the Wildlife Management Institute⁹.
6. In the Executive Summary Mr. Eveland states that, “…a few state employees have changed the mission of the Pennsylvania Game Commission to fit their personal agenda…” and that “…three men redesigned the deer management program at their personal discretion to serve the interests of foresters and environmentalists instead of serving the interests of sportsmen for recreational hunting…” but nowhere does he provide quotations or written documentation of his claims. Hearsay has no place in scientific management of natural resources.
7. Information presented by Mr. Eveland on deer harvest and deer densities is not referenced, so the reader has no idea if the data are true or made-up.
8. Eveland’s claim that the reduction in the deer herd provided, “Virtually no benefits for science, tree seedling regeneration, the forest ecosystem, for commercial forestry, for biodiversity, for deer health or for society and the commonwealth’s economy“ is false on all counts: Scientific articles produced in Pennsylvania have shown that the reduction in the deer herd has been associated with a decrease in deer impact levels on commercially valuable tree seedlings¹⁰, with a reduced need for, or elimination of, the need for expensive fencing to protect tree seedling regeneration from deer browsing¹¹, with an increase in the health and reproductive status of wildflowers shrubs¹², and with an increase in deer health, as measured by antler characteristics and body weight of harvested deer¹³.
9. Eveland produced no data to support his claim that society and the commonwealth’s economy received no benefits as a result of reduction in deer numbers, nor did he cite references to support his claim that sportsmen and recreational hunting also received no benefits as a result of reduced deer abundance. The fact that deer quality improved after reduction in deer abundance¹³ rebuts his claim about hunters not realizing any benefits. The fact that knowledgeable and skillful (alpha) hunters who harvested deer on a large study area maintained a satisfaction level of 7 out of 10 where a score of 10 is highly satisfied¹³ rebuts his claim about sportsmen and recreational hunting not realizing benefits from reduction in deer abundance.
10. Eveland claims that, “The negative impacts to the natural ecosystem, society, and economy are severe, unjustified, and increasing yearly” without mentioning or documenting just what those negative impacts are. He further claims that,“The deer herd has been reduced to nearly unhuntable numbers in some areas” without offering documentation. He provides no documentation of his claim that, “Upwards of 200,000-300,000 sportsmen have stopped hunting as a result of deer reduction, and the rate of youth-hunter recruitment is declining and unable to replace the loss of adults.”  Ditto for the claim that, “Since 2001, upwards of $10 billion has been lost in Commonwealth economic activity due to deer reduction which is increasing at the rate of $500 million to $1.16 billion each year with $92 million in annual tax revenue losses.”  Mr. Eveland stated that, “Deer reduction has become a crisis that likely represents the greatest conservation mistake in the over-100-year history of the Pennsylvania Game Commission.” I would contend that bringing the Pennsylvania deer herd down to densities identified with the herd being in balance with other natural resources represents the greatest conservation achievement of the PA Game Commission.
11. Eveland states that “Pennsylvania Game Commission has ignored the creation of adequate habitat for deer, grouse, and an estimated 150 species of wildlife – placing Pennsylvania’s State Mammal, State Bird, and wildlife resources at risk.” Actually, science has shown that deer density exceeding 15 deer per square mile has a significant and negative impact on wildlife habitat, including herbaceous plants they utilize as forage, and on wildlife species (including deer)^14,15,16.
12. Eveland incorrectly asserted that as a result of changes in deer management, “Upwards of 200,000-300,000 sportsmen have stopped hunting as a result of deer reduction.” This statement is false, as in 2012 the PA DCNR¹⁷ stated, based on PGC data, that the number of general hunting licenses sold by the PGC declined from 1.05 million in 2001 to about 933,000 in 2011, representing a loss of approximately 117,000 hunters.
13. Eveland’s description of the FSC Certification of the PA Bureau of Forestry is similarly deceptive and flat-out wrong. He stated that, “In 1998, DCNR had entered into an agreement with the Forest Stewardship Council – a German-based environmental organization that was partnered with the International Rainforest Alliance – in which DCNR would pay FSC an annual fee, and in return FSC would grant DCNR an annual Green Certification Award.” It is true that the DCNR pays an annual fee to the FSC, but that fee has been used exclusively to determine whether the DCNR was making progress on deficiencies noted the initial review by the certification team. Paying a fee does not, contrary to what Mr. Eveland contents, guarantee annual renewal of a certificate signifying compliance with sustainability standards.  Mr. Eveland also asserted that, “…FSC’s regional representative, DCNR’s chief of forestry, and Pennsylvania Game Commission’s chief of wildlife management conspired to use this opportunity (certification) to permanently reduce the deer herd. The trio arbitrarily included a provision in the DCNR/FSC Green Certification agreement that the Game Commission would need to comply with herd reduction in order for DCNR to be granted the annual award.” I know this assertion is false because I was the ecologist on the Scientific Certification System ¹⁸ team that performed the certification assessment of the PA Bureau of Forestry and it was a recommendation of the team, rather than the three men identified by Mr. Eveland, that the DCNR should take action to reduce the deer herd as a condition of continued certification.
14. Eveland claimed that “The Legislative Budget and Finance Committee determined that as of 2011 the resulting annual DCNR gain in revenue was about $1.2 million, while the cost to Commonwealth economic activity – primarily to family businesses and rural communities – was a minimum of $501.6 million per year. The LB&FC further calculated that a minimum of $40 million in annual tax revenue was being lost as a result of the deer-reduction program — $25 million in lost annual state tax revenue and $15 million in local taxes. By 2017, these annual impacts had increased to $1.16 billion in losses to our economy and $92.5 million in lost tax revenue. In fact, the only report issued by the Legislative Budget and Finance Committee including 2011 was a report issued the succeeding year ²⁴ (2012) that dealt with costs and benefits of FSC Certification of DCNR Forests and the report indicated positive economic benefits accruing to the PA BOF from the certification. The numbers quoted above by Mr. Eveland do not appear in any Legislative Budget and Finance Committee reports that I was able to find searching the Legislative Budget and Finance Committee website for published reports. Either Mr. Eveland made up those data, or derived them from a source not identified as a report by the Pennsylvania Legislative Budget and Finance Committee. If such reports exist, he should have documented them properly so his claims could be verified.
15. The claim by Mr. Eveland that, “…The need to increase forest tree-seedling regeneration was a principal reason Pennsylvania Game Commission used to justify permanent reduction of the herd.  However, after independent scientific assessment, the forest regeneration theory has proven to be a myth – false science is a blatant untruth for which he provided no evidence.”  In fact, just the opposite is true. Established science has proven that forest tree seedling regeneration improves dramatically and significantly after reduction in deer density²⁰.
16. The claim by Mr. Eveland that, the Pennsylvania Game Commission has “…declined to create adequate habitat because cutting trees would have generated tens-of-millions-of-dollars for the Pennsylvania game Commission and eliminated the agency’s justification for a license-fee increase – a deception and violation of The Pennsylvania Constitution, Article I, Section 27” is another example of unsubstantiated and untrue statements he makes regarding wildlife management by the Pennsylvania Game Commission. Harvesting trees may produce valuable wildlife habitat, if the basis for such (an abundant and diverse amount of tree seedlings, shrubs, and herbs) exists prior to tree harvest. In fact, whether trees may be harvested is determined, as any forester worth their salt knows, by the diversity and abundance of seedlings of commercially valuable seedlings present prior to timber harvest. The trained foresters on the Pennsylvania Game Commission staff cannot and will not commence harvesting trees until and unless adequate amounts and diversity of tree seedling species are present prior to tree harvest. They will not proceed with tree harvest when the understory is comprised of ferns, grasses and seedlings of undesirable tree species, such as beech and striped maple, as these plants would form the succeeding forest which would have no commercial value and would be depauperate regarding diversity of understory vegetation and wildlife habitat. This condition perfectly describes forest understory as affected by overabundant deer herds²¹ which existed prior to reduction of deer abundance.
17. The Executive Summary on page 5 of the unpaged document is not an executive summary at all. Such summaries provide a succinct summary of the gist of the document and usually consist of one paragraph of no more than one page in length. The Summary that Mr. Eveland provided is a 4-page rant rather than a concise summary of the contents of his document. However, I rebut below portions of his executive summary:
    2. Eveland asserted that management for MSY of the deer herd “… served the recreational interests of the many millions of wildlife enthusiasts and outdoor-loving citizens of the Commonwealth.” The truth is, managing for MSY of the deer herd, while creating an abundant deer herd, basically simplified and modified wildlife habitat and understory vegetation to the point where songbird populations and diversity declined, as did herbaceous vegetation and tree seedling regeneration². This severe alteration of the diversity and abundance of other wildlife species and understory vegetation did not “serve the recreational interests of many millions of wildlife enthusiasts and out-door loving citizens of the Commonwealth” as Mr. Eveland asserted. Rather, it served the interests of only one group, those hunters who wanted a deer herd at maximum density for hunting.
    3. Eveland stated without reference that, “A 2009 study that was funded by the Pinchot Institute discovered that every state in the nation used the MSY method of game management in one form or another except one state — Pennsylvania.” I could not find a report of this study, and the Pinchot Institute manager of publications, Will Price, was not aware of such a publication. However, I did find a 2012 publication by the Pinchot Institute titled. “Pennsylvania’s Forests, How They are Changing and Why We Should Care.”²². Excerpts from this publication include, “Deer have made a magnificent recovery during the second half of the 20th century, to the point of overabundance. Deer now crowd backyards, roadways, and forests. In many of these places, they are free from pressures that once kept herds in check. Even in the large forests of the central state, there are fewer pressures than in the past, as hunting is in decline. Experts estimate that there should be no more than 15 to 20 deer per square mile, but many places in Pennsylvania host more than 50 deer per square mile. In heavily settled areas, where hunting pressure is light or non-existent, it is not unusual to have more than 75 deer per square mile. The hunger of an oversized deer population exacts a heavy toll on delicate seedlings, shrubs, and flowering plants. The result is a forest missing a future generation of trees and a forest floor stripped of much of its diversity. In the early 1900s, one western Pennsylvania forest hosted 41 species of plants; by the mid-1990s, almost half had disappeared. The rarest of Pennsylvania wildflowers remain only in sanctuaries inaccessible to deer. A 10-year study by the US Forest Service determined that more than 20 deer per square mile lead to a complete loss of cerulean warblers, yellow-billed cuckoos, indigo buntings, and other migratory birds.” The Pinchot report promoted “…cooperative deer management because deer roam, breed, and browse across multiple ownerships and, in general, are too much for one landowner (public or private) to handle. Managing deer typically involves putting up fences to keep deer out of some areas. This practice is expensive and the budget for fencing state lands runs into the millions. Most individual landowners cannot afford to underwrite these costs and so the forests suffer.” The report offered the Kinzua Quality Deer Cooperative (KQDC) as a solution to deer overpopulation and impacts on forest resources to confront this dilemma. “…Deer permits offered by KQDC landowners (through the Game Commission’s Deer Management Assistance program) sparked more hunting and more deer harvested. Over successive years, deer declined from almost 30 per square mile to 12 per square mile. As deer numbers declined individual deer grew bigger each year. The KQDC reaffirmed the notion that, without hunting, deer would overrun the forests, fields, yards, and roads—declining in size and health as their forage became scarce. In this respect, hunters are critical to sustaining ecosystems.”
    4. Eveland makes a number of undocumented statements, including a false claim that the deer herd was reduced from 1,500,000 deer statewide to 600,000 (a 60% reduction) from 2000 to 2004 and by 90% in some unspecified “other” regions, a claim that the Pennsylvania game Commission president wanted to reduce deer density to 5-6 deer per square mile, and an undocumented claim that there were only 1-2 deer per square mile throughout large regions of Pennsylvania. Mr. Eveland provides no evidence to support these claims of vast reductions in the deer herd. In point of fact, Pennsylvania Game Commission deer biologists with a PennState University wildlife professor published a peer-reviewed article²³ in a prestigious wildlife publication where they state, based on data collected from the PA deer herd, that the deer herd was reduced from 1,490,000 deer in 2000 to 1,140,000 deer by 2005, a 23% reduction rather than the 60% reduction claimed by Mr. Eveland. Furthermore, data provided by the DCNR on estimates of deer density 2000-2010 rebut Mr. Eveland’s contentions about the large drop in deer density in PA. * based on data provided by the PGC                                                                        Also, the Legislative Budget & Finance Committee of the PA General Assembly²⁴ stated that total number of deer in PA on all Deer Management Units (with no data from two) was 886,837 in 2009, 878,627 in 2010, 987,943 in 2001, 1,035,142 in 2012, 1,080,008 in 2012 and 1,082,450 in 2014, not at all reflective of the great decline in deer abundance Mr. Eveland asserts that occurred. Regarding the target deer density of 5-6 deer per square mile Mr. Eveland attributes to the PA Game Commission president, I was unable to find documentation of such. What I did unearth, was the recommendation in 2001²⁵ for a reduction of the deer herd by 5%, rather than a recommendation to reduce the deer herd to 5-6 deer/square mile.
18. Eveland stated that …”A member of PGC’s deer team stated in a private conversation, ‘Deer have literally been exterminated in some regions and still regeneration has not returned.’” He further alleged that, “Regarding PGC’s control of Legislative oversight, a wildlife management chief bragged in private conversation that, “I get what I want; I baffle them with b__ s__”. Unless Mr. Eveland has proof of these claimed statements, they can only be taken as intentionally inflammatory statements designed to discredit Pennsylvania Game Commission employees without proof—in other words, intentional and unsupported defamation. Such statements have no place in professional discourses regarding management of deer or other natural resources and should be disregarded as having no merit nor value save to sow doubts on the professionalism of Pennsylvania Game Commission employees. The words “private conversation” should be viewed skeptically as they are designed to prepare recipients of the “information” that they will be exposed to hearsay in support a position for which the author has no factual information.
19. Eveland stated that, “The Legislative Budget and Finance Committee determined that as of 2011 the resulting annual DCNR gain in revenue was about $1.2 million, while the cost to Commonwealth economic activity – primarily to family businesses and rural communities – was a minimum of $501.6 million per year. The LB&FC further calculated that a minimum of $40 million in annual tax revenue was being lost as a result of the deer-reduction program — $25 million in lost annual state tax revenue and $15 million in local taxes. By 2017, these annual impacts had increased to $1.16 billion in losses to our economy and $92.5 million in lost tax revenue.” This information was published by the Unified Sportsmen of Pennsylvania in a publication authored by Mr. Eveland. These data overstate information released by The Legislative Budget and Finance Committee in its 2010 report¹⁹, which stated, “The decline in hunter participation between 2001 and 2011 therefore represents a potential loss of $285 million in direct economic activity.” The report adds this caveat: “It would be overly simplistic, however, to link a reduction in either the PA deer herd or the number of general licenses sold directly to DCNR’s forest certification program, as many factors are involved in these trends.” I was unable to find any documentation of the numbers produced by Mr. Eveland in the form of alleged reports issued in 2011 and 2017 by the Legislative Budget and Finance Committee. Using unproven numbers published by an organization of disgruntled deer hunters to discredit the Pennsylvania Game Commission cannot be taken seriously nor used to direct management of the Pennsylvania deer herd. In contrast, a report by the Legislative Budget & Finance Committee of the PA General Assembly²⁴ stated that, “The economic benefits of FSC certification are modest, but may increase in future years. A study done of PA timber sales found that between 2001 and 2006, DCNR earned a premium of about $7.7 million by selling to FSC-certified buyers. This premium—about 10%—is higher than most studies find (typically 6% or less) and was largely attributable to one species, black cherry.”
20. Eveland disputed studies conducted by “… PGC and DCNR … proving that deer were destroying new forest regeneration to the detriment of red oaks for foresters and understory shrubs and wildflowers as habitat for nongame wildlife,” by stating that .”…multiple studies dispelled this belief...” and that rather “…it was discovered that the lack of regeneration had not been caused by deer, but by aging forests with 80-125-year-old trees. Tightly closed canopies were preventing sunlight from reaching the forest floor. In addition, Penn State had told PGC to no avail that increasingly acidic soils from acid precipitation was also responsible for low and decreasing levels of understory regeneration.  Mr. Eveland needs to document what the “multiple studies” are if he wants any credibility to his claims. In point of fact, maturing forests, including old growth, are not characterized by total overstory canopy closure but rather by multiple openings of various sizes that contain tree seedlings that form the next forest when the overstory is removed by natural disturbance or timber harvest. The acid rain theory (that it’s acid rain and not deer browsing that causes failures of advanced regeneration in the forest understory) advanced by Dr. William Sharpe of PennState University is easily debunked by comparing vegetation inside and outside deer-proof fenced exclosures. Unless acid rain falls in patterns that exclude falling within deer-proof exclosures (of which there are many in forests impacted by acid rain) it cannot be acid rain that causes regeneration failures.
21. Eveland claimed that, “For some time legislators and sportsmen had wondered why PGC was not cutting more timber and making millions of dollars annually from their mature forests that at 80-125 years old have grown to a very marketable size of 20-24 inches in diameter. PGC’s failure to cut timber for desperately needed wildlife habitat was recently explained by a retired PGC chief: “The Game Commission is playing a political game with Legislators.  If they cut the amount of timber that’s needed for wildlife habitat, they’ll make a lot of money and won’t be able to justify a license increase.” is undocumented and misleading hearsay purportedly made by a retired PGC chief (but no proof is offered concerning the claim and who made it.)  Also, data from the Legislative Budget & Finance Committee of the PA General Assembly²⁴ indicates timber revenues from state game lands was 6.6 million dollars in 2011-2012; 7.2 million dollars in 2012-2013; and 7.1 million dollars in 2013-2014 – refuting the claim by Mr. Eveland that PGC has failed to cut timber.
22. Eveland incorrectly concludes in his report that, (1) no significant benefits have resulted after 17 years of herd reduction—not for science, society, nor economy—while the negative impacts to the future of sport hunting and the Commonwealth have been great; and (2) that PGC’s deer-reduction program is designed to serve foresters and fringe environmentalists at the expense of wildlife resources, sportsmen and recreational hunting, rural economies and the outdoor industry, and the general outdoor interests of Pennsylvania’s citizens.” This assessment is faulty. The reduction in the deer herd over the last 10 or so years has resulted in improved wildlife habitat, improved understory vegetation, and improved deer condition¹². Improved understory vegetation (species composition, and horizontal and vertical structure of ground and shrub vegetation) means improved habitat for dependent wildlife species, including turkey, grouse, and hares.
23. Eveland’s statements that, “…lumber coming from DCNR’s red oak and black cherry trees was no different than lumber from Farmer Brown’s oak and cherry trees, nor was it superior to trees that had grown during the same time period on almost any other public or private forest lands in the Commonwealth. While DCNR had sufficient revenue to purchase the annual award, according to a 2011 Pennsylvania Legislative Budget and Finance Committee report, many smaller landowners were financially unable to purchase FSC’ green certification award and would be at a disadvantage in selling their timber – placing these small operators at risk and forcing some previously forested areas to be converted to agriculture.  When trying to sell the award to a small family-owned lumber company, the representative told the owner that he could purchase the certification without worrying about making any management changes to his forest holdings, stating: “I’m an environmental opportunist, not an environmentalist “are false and misleading. It is true that certified lumber has little if any superior quality to that grown on uncertified forestland, but quality of timber is not the goal of certification.  Certified forestry operations do not “buy certification.” Rather, the initial fee, and subsequent fees assessed to ascertain whether actions need to be taken to correct deficiencies noted in initial assessments are used to pay certification companies to conduct the initial assessment and succeeding audits. Additionally, certified timber is grown on forestlands certified as managing for all forest resources sustainably, with special emphasis on diversity and quality of other forest resources. It is true that smaller, private woodlot owners may be unable to pay for the certification process and obtain certification, but that imposes no financial burden on them. They can still sell their timber to buyers. Some form aggregates of forest landowners in group assessments to spread out the cost, but again, lack of certification does not impose financial hardship on small woodlot owners or others who do not seek certification.
24. Regarding costs of certification of the DCNR forest management program, Mr. Eveland claimed that, “The Legislative Budget and Finance Committee determined that as of 2010 the annual DCNR gain in revenue from the green-certification/deer-reduction scheme was about $1.2 million per year, while the cost to Commonwealth economic activity – primarily to family businesses and rural communities – was a minimum of $501.6 million per year. The LB&FC further calculated that a minimum of $40 million in annual tax revenue was being lost as a result of the deer-reduction program — $25 million in lost state tax revenue and $15 million lost annually in local taxes. By 2017, these annual impacts had increased to $1.16 billion in losses to the state’s economy and $92.5 million in tax-revenue losses.” These claims are not supported by the 2012 report of the Legislative Budget and Finance Committee report titled, “The Costs and Benefits of FSC Certification of DCNR Forests.” Instead, the report found that, 1.) “DCNR has a five-year contract for $101,736 covering the recertification audit and the four annual reviews between recertifications. These costs represent about a 4.8 cents per acre over the five-year period, or about a penny a year per acre.” The Heinz Endowments program, through a grant by the Gifford Pinchot Institute for Conservation, paid for the initial certification assessment, at no cost to Pennsylvania taxpayers. Additional findings of the LB&FC regarding costs/benefits of certification included: 2.) “DCNR has a five-year contract for $101,736 covering the recertification audit and the four annual reviews between recertifications. These costs represent about a 4.8 cents per acre over the five-year period, or about a penny a year per acre;” 3.) “DCNR characterizes the benefits of FSC certification as important, but largely for nonfinancial reasons. DCNR cites the primary benefits being an independent review of its forest management practices; improved staff morale in knowing the department meets certification standards; and added credibility in assuring the public that it is managing state-owned forests in a professional and sustainable manner;” 4.) “Several studies, including one of DCNR timber sales, have found that FSC certification can also provide modest financial benefits, often on the order of a 5 percent premium over noncertified lumber. A 2008 study of DCNR timber sales found that, between 2001 and 2006, FSC-certified buyers of Pennsylvania state forest timber paid approximately $7.7 million more for this timber than what would have been earned had all buyers been non-certified. According to the study, higher bid prices offered by FSC-certified buyers (primarily for black cherry) translated into roughly a 10 percent increase over what would have been earned in the absence of certification. The study also found that by 2006, FSC-certified buyers accounted for nearly two-thirds of the dollar value of all state forest timber sales²⁴” and, 5.) “In April 2011, DCNR’s State Forester reported to the Pennsylvania Game Commission that DCNR has seen positive signs of recovery in many of state forests as a result of deer management policies of the past 10 years,” Nowhere in the report did I find any of the costs to Pennsylvania of certification asserted by Mr. Eveland, nor could I find any corroboration of his claimed costs in other reports of the PA Legislative and Budget Committee. I examined the comprehensive, 2010 report by the PA Legislative and Budget Committee titled, “Examination of Current and Future Costs and Revenues from Forest Products and Oil, Gas, and Mineral Extraction on Pennsylvania Game Commission Lands” and found no corroboration of Mr. Eveland’s asserted costs of certification.
25. In his assessment of the DCNR monitoring report¹⁶ on deer impact in a 2006 report, Mr. Eveland got it half right, but made inferences that were wrong and misleading. Concerning the report, Mr. Eveland stated, “DCNR conducted possibly the most comprehensive forest regeneration/browse study in the history of the agency – counting tree seedlings and saplings to six feet in height and measuring the amount of browsing by deer. According to the report, DCNR crews surveyed “47,327 individual plots along more than 1,600 miles of transects, with 88% coverage of the state forest system.”  In 2006, DCNR published the results of their survey in a 30-page technical report.  All seedling browsing by deer was listed in five categories: none, slight, moderate, heavy, and severe.” This is the part Mr. Eveland got right. But he went on to say, “The results shocked the two agencies, discovering that over 68% of young trees were not browsed at all, and another 21% were only lightly browsed – representing little to no browsing of a combined 89% of seedlings and saplings.  Another 7% were moderately browsed, indicating that 96% of all samples fell within the unbrowsed to moderately browsed categories.  Therefore, only 4% of seedlings and saplings from the 47,327 survey plots covering 1,600 miles were categorized as heavily or severely browsed.” Actually, on average, 4 percent of plots contained seedlings that were heavily to severely browsed not 4% of seedlings. However, if one looks at the data from Table 2 of the report, for a number of species (15 of 51) the percent of plots containing those species heavily to severely browsed was 10-29% or more. These species are known to be preferred by deer (greenbrier, black gum, hawthorn, white oak, chestnut oak, sassafras, elderberry, red oak, aspen, witch-hazel, ash, magnolia, basswood, Virginia creeper). More telling, the percent plots containing individual species of any damage level was very low: ranging from less than 0.10 percent of all plots to 39%. Thirty four of the 51 species occurred on less than 5% of all plots. In other words, most plots did not have any seedlings of species evaluated, most likely because heavy deer browsing over the last century removed most and kept them from recurring. When seedlings are so scarce that the highest percent of plots containing seedlings of individual species (22.6% to 40%) are populated by species avoided by deer (beech, striped maple, mountain laurel, and huckleberry) it is clear that there was very little of anything available for deer except species they do not prefer. Another factor to consider in evaluating the report is that the period of evaluation was for only two years (2006-2007) which was 3 years after the DMAP program (for increasing harvest of antlerless deer) was initiated.  Likely percent plots with individual seedling species was much lower prior to deer reductions resulting from the DMAP and concurrent buck-doe seasons (2003). And, it is likely that a second survey conducted in 2010 or later, when the DMAP and concurrent seasons had been in place for longer would have shown marked increase in percent plots with seedlings of seedling species preferred by deer, as was the case on the Kinzua Quality Deer Cooperative¹².  Additional parameters for evaluating deer impact (percent plots with no impact on regeneration and percent plots no regeneration of any species) are part of the protocol²⁶  for estimating deer impact but they were not used in this report. On forest landscapes so heavily browsed by deer that there are few seedlings of any species, these broad estimators of deer impact are more informative. Finally, Mr. Eveland’s’ comment that, “Shortly thereafter (publication of the monitoring report), the study’s two principal architects, Merlin Benner from DCNR and Gary Alt from PGC, resigned in the face of their dramatic failure – possibly to avoid repercussions that were expected to result once the Legislature realized that they had perpetrated such a grand scientific, social, and economic error” is mere speculation without a shred of corroboration. [Note from Josh First: I personally knew both Merlin Benner and Dr. Gary Alt at the time being discussed here, and I have never before heard, read, or encountered any information that supports John Eveland’s allegation that the two scientists had to resign, did resign, or were criticized for their scientific work. Merlin Benner left public service to start several businesses doing work he loves, and Gary Alt was openly burned out by the Pennsylvania “Deer Wars” and he happily left public service to become a much more relaxed private sector naturalist providing wildlife tours to people who are interested in wildlife science]

Inaccurate and Misleading Assertions Concerning Pennsylvania Game Commission State Law/Constitution

1. Eveland claims that the deer management program “was and remains a gross and deliberate violation of Title 34, Section 322 (c) (13). This state law states that a duty of the Pennsylvania Game Commission is to “serve the interest of sportsmen by preserving and promoting our special heritage of recreational hunting and furtaking by providing adequate opportunity to hunt and trap the wildlife resources of this Commonwealth.” However this duty does not describe preserving and promoting hunter heritage of hunting and furtaking by providing as many deer or furbearers as hunters want. It simply states that hunters will have an adequate opportunity to hunt and trap and does not equate “adequate opportunity” with an unlimited quantity of deer to shoot or furbearers to trap. Mr. Eveland further stated that the reduction in deer density was, “…initiated without the benefit of a cost/benefit analysis and without approval by the Joint Legislature, and represents a gross and deliberate violation of Title 34 State Law: Section 322(c) (13)”. I am not aware that a mandated function of the PA legislature is to approve of Pennsylvania Game Commission management actions. Mr. Eveland’s erroneous claim that the reduction in the deer herd is a gross and deliberate violation of Title 34 State Law, Section 322(c)(13) is false and misleading
2. Eveland claims that the Pennsylvania Game Commission violated Article I, section 27 of the Pennsylvania Constitution, stating that, “the Pennsylvania Game Commission has ignored the creation of adequate habitat for deer, grouse, and an estimated 150 species of wildlife – placing Pennsylvania’s State Mammal, State Bird, and wildlife resources at risk – a violation of The Pennsylvania Constitution, Article I, Section 27,” Actually, Article I, Section 27 of the Pennsylvania Constitution States that, “…the people have a right to clean air, pure water, and to the preservation of the natural, scenic, historic and esthetic values of the environment.” The article further states that, “Pennsylvania’s public natural resources are the common property of all the people, including generations yet to come. As trustee of these resources, the Commonwealth shall conserve and maintain them for the benefit of all the people.” Mr. Eveland claims without proof that the Pennsylvania Game Commission does not manage habitat for the benefit of wildlife species.  He asserts that the Pennsylvania Game Commission does not create wildlife habitat because it does not harvest timber (which can only relate to Pennsylvania State Gamelands – about 9% of forestland in Pennsylvania. The other 91% of Pennsylvania forestlands are owned/managed by other persons/entities over whom the Pennsylvania Game Commission has no management authority regarding timber management). Article I, Section 27 can in no way be construed to mean that the Pennsylvania Game Commission must harvest timber to avoid risking the welfare of 150 wildlife species.
3. Eveland stated that the reduction in deer density was, “…initiated without the benefit of a cost/benefit analysis and without approval by the Joint Legislature, and represents a gross and deliberate violation of Title 34 State Law: Section 322(c) (13).” It is not a mandated function of the Pennsylvania legislature to approve of Pennsylvania Game Commission management actions.

Favoring a single, minority stakeholder group over a majority of Pennsylvanians affected by deer management.

1. It must be acknowledged that the stakeholder groups the Pennsylvania Game Commission is accountable to include more than just deer hunters who want to maximize deer density for hunting. Other stakeholders negatively affected by overabundant deer include grouse, turkey, and hare hunters, public and private forest landowners attempting to provide sustainable timber harvests, motorists who collide with deer, landowners whose landscaping is decimated by overabundant deer, and managers of public lands mandated to optimize diversity of forest resources.
2. It is true that revenues provided by hunting licenses and federal Pittman Robertson funds allotted to Pennsylvania (based on number of hunting licenses sold) provide the financial underpinning of the Pennsylvania Game Commission. However, Mr. Eveland ignores the reality that private landowners and public agencies (e.g., state and national parks, state and national forests) provide deer habitat, provide deer forage, and provide hunter access to their lands with their own financial resources and absorb the costs of negative deer impact on their agricultural crops and forest regeneration caused by the high deer densities sought by hunters. Furthermore, deer hunters do not reimburse these landowners for the services, habitat, and access they provide, nor for the damage deer cause. With the exception of the system of State Gamelands in Pennsylvania (which are managed by the Pennsylvania Game Commission and only comprise approximately 9% of forested land in Pennsylvania), the costs of providing deer habitat, maintenance of hunting access, and absorption of costs of overabundant deer herds are borne by landowners and managers of private and public forestlands not in the Gamelands system and are not supported by deer hunters (reference my papers).
3. In Appendix C of his report, Mr. Eveland complains about the DCNR plan to promote and retain old growth forests within the system of State Forests. Unfortunately, he is unaware that the stakeholders served by the Pennsylvania Bureau of Forestry, and its parent organization, the Pennsylvania Department of Conservation and Natural resources include all citizens of Pennsylvania, not just deer hunters who want more deer. For clarification, the mission statements, and actions by which these DCNR and BOF missions are to be accomplished are:
   1. The Pennsylvania Department of Conservation and Natural Resources’ mission²⁷ is to ensure the long-term health, viability and productivity of the Commonwealth’s forests and to conserve native wild plants. To achieve this mission, the DCNR will:
4. Advocate and Promote Forest Conservation
5. Provide Forestry Information and Outreach
6. Prevent and Suppress Wildfires
7. Protect the Forest From Destructive Insects and Diseases
8. Conserve Native Plants
9. Conserve Private Forest Land
10. Promote Community Forests and Tree Planting
11. Manage the Certified State Forest System
12. Protect Water Quality
13. Sustainably Harvest Timber
14. Manage Natural Gas Activity
15. Provide Forest Recreation Opportunities —Featured recreational activities include hunting, along with scenic driving to hiking, camping, and snowmobiling. The Bureau maintains thousands of miles of trails, roads and related infrastructure to accommodate state forest visitors and ensure quality low-density recreational experiences. Note that hunting is one of several recreational activities the DCNR will promote and enhance by maintaining hunting access and ensuring quality, low-density recreational experiences.  Nowhere is maximizing number of deer for deer hunters identified as a goal.
16. b) The mission of the DCNR Bureau of Forestry²⁸, a division within the Pennsylvania Department of Conservation and Natural Resources, is to ensure the long-term health, viability, and productivity of the commonwealth’s forests and to conserve native wild plants. The bureau is to accomplish this mission by:
17. Managing state forests under sound ecosystem management, to retain their wild character and maintain biological diversity while providing pure water, opportunities for low-density recreation, habitats for forest plants and animals, sustained yields of quality timber, and environmentally sound utilization of mineral resources.
18. Protecting forestlands, public and private, from damage and/or destruction by fires, insects, diseases, and other agents.
19. Promoting forestry and the knowledge of forestry by advising and assisting other government agencies, communities, landowners, forest industry, and the general public in the wise stewardship and utilization of forest resources.
20. Protecting and managing native wild flora resources by determining status, classifying, and conserving native wild plants.

 Unsupported, conspiracy-theory type statements

Sprinkled throughout his report, Mr. Eveland makes a number of conspiracy-theory type statements about various individuals whom he claims, without proof, colluded to reduce deer density, and mandated the findings and recommendations of the certification assessment of the PA DCNR. A few such statements are appended below:

1. “…in 1998, the PGC established the Deer Management Working Group (DMWG) to review the existing program and provide recommendations regarding the creation of a new statewide deer management program. Scot Williamson (the principal representative of the Wildlife Management Institute (WMI)) was selected by the PGC as the group’s chairman. This action was designed to create the perception that the findings and recommendations of the DMWG had resulted from an unbiased independent assessment of the state’s deer management program. In reality, however, the new deer-reduction/ecosystem-management program had already been designed by Gary Alt and Calvin DuBrock at the request of Bryon Shissler and Dan Devlin (DCNR).”
2. “Three men who all despised deer and who blamed deer for virtually all maladies that befell the forest ecosystem (FSC’s regional representative (Bryon Shissler), DCNR forester Dan Devlin, and PGC’s chief of wildlife management (Calvin DuBrock), who was, himself, not a hunter) conspired to use this opportunity to permanently reduce the deer herd. A provision was inserted into the DCNR/FSC green certification agreement stating that the Game Commission would need to comply with a hoped for, new herd-reduction program in order for DCNR to be granted the annual award.  While in reality this deer-reduction requirement was not the case but simply a ruse by the three men (in that DCNR would receive the annual award from FSC as long as they paid FSC the required annual fee), they succeeded in convincing the governor, who adjusted the Commission’s board of game commissioners and executive staff toward achieving their desired personal herd-reduction goal.  Therefore, herd reduction was initiated for two reasons: (1) to increase timber-sale revenue for DCNR, and (2) to achieve the anti-deer, environmental agenda of three men.”
3. “Three men redesigned the deer management program at their personal discretion to serve the interests of foresters and environmentalists – not just instead of serving the interests of sportsmen for recreational hunting, but at the expense of sportsmen and recreational hunting.”
4. In 1998, DCNR had entered into an agreement with the Forest Stewardship Council … in which DCNR would pay FSC an annual fee, and in return FSC would grant DCNR an annual Green Certification Award. According to this mutually-beneficial scheme, the annual Green Certification Award would give environmentally-minded retail and wholesale customers the impression that lumber from DCNR’s state forests was superior to other sources of wood products, and, therefore, domestic and international sales of DCNR lumber would increase. Three men (FSC’s regional representative, DCNR’s chief of forestry, and PGC’s chief of wildlife management) conspired to use this opportunity to permanently reduce the deer herd. The trio arbitrarily included a provision in the DCNR/FSC Green Certification agreement that the Game Commission would need to comply with herd reduction in order for DCNR to be granted the annual award.  While in reality this was not the case but simply a ruse by the three men, they succeeded in convincing the governor, who adjusted the Commission’s board of game commissioners and executive staff toward achieving herd reduction.” 
5. “It is important to note that prior to DCNR’s signing of the Green-Certification agreement with FSC in 1998, forestry agencies from other states were invited to the meeting in Harrisburg toward soliciting their participation in the program along with DCNR.  However, according to written records these states left the meeting and refused to participate in the program, stating that the Green-Certification program was based on politics, not on science.”
6. “In 2008, an audit was developed consisting of 15 questions that had been pre-designed by PGC, Tim Schaeffer, and a small group of deer-reduction “orchestrators” to provide a positive response in favor of  PGC’s deer program – attempting to validate the program as being based on “sound science”.  Levdansky and Tim Schaeffer had promoted this audit to the House Game & Fisheries Committee and the Legislative Budget & Finance Committee for several months.  Once approved, to further assure the outcome of the audit, by selecting Scot Williamson as the auditor, the legitimacy of PGC’s deer-reduction program was being investigated and determined by the person who had developed the program for the PGC 10 years before as chairman of PGC’s DMWG… Therefore, both the audit and the auditor were biased, and, thus, the audit-process was fraudulent – designed to deceive the board of commissioners, legislators, sportsmen, and the public to believe that PGC’s deer-reduction program was based on noble ideals that were in the best interest of all parties.”

In summary, Mr. Eveland’s comments are based not on established science as supported by research but instead on beliefs and culture of a minority of Commonwealth residents. Hunting deer for 50 years does not make a deer scientist, but rather a seasoned deer hunter. Persons hunting deer for recreation do not put themselves in the shoes of foresters whose regenerating seedlings are wiped out by overabundant deer, nor do they commiserate with farmers whose alfalfa crop has been decimated by too many deer. Deer management should be based on the needs of all stakeholders affected by deer, rather than only on the desires of hunters or businesses that support hunting.

References

1. Leopold, A. 1943. Deer irruptions.   Transactions of the Wisconsin Academy of Sciences, Arts and Letters. Pages 351-366
2. deCalesta, D. S., and S. L. Stout. 1997. Relative deer density and sustainability: a conceptual framework for integrating deer management with ecosystem management. Wildl. Soc. Bull. 25:252‑258.

3. McCullough, D. R. 1979. The George Reserve Deer Herd: Population Ecology of a K-selected  Deer Herd. University of Michigan Press.

4. Rooney, T. P. 2001. Deer impacts on forest ecosystems: a North American perspective.  Forestry 74: 201-208.

5. deCalesta, D. S. 1994.  Impact of white‑tailed deer on songbirds within managed forests in Pennsylvania.  J. Wildl. Manage. 58:711‑718. 5.

6. McShea, W. J., and J. H. Rappole. 1992. White-tailed deer as keystone species within forest habitats in Virginia. Virginia Journal of Sciences 43:177-186.

7. Rooney, T. P., and W. J. Dress. 1997. Species loss over sixty-six years in the ground-layer vegetation of Heart’s Content, an old-growth forest in Pennsylvania, USA. Natural Areas Journal 17: 297–305.

8. Horsley, S.B., S.L. Stout, and D.S. deCalesta. 2003. White-tailed deer impact on the vegetation dynamics of a northern hardwood forest. Ecol. Appl. 13(1):98-118

9. Wildlife Management Institute. 2010. The deer management program of the Pennsylvania Game Commission: a comprehensive review and evaluation. The Wildlife Management Institute, Washington D.C., USA.
10. Tilghman. N. G. 1989. Impacts of white-tailed deer on forest regeneration in northwestern Pennsylvania. Journal of Wildlife Management 53:524-532.
11. Stout, S. L., A. A Royo, D. S. deCalesta, K. McAleese, and J. C. Finley. 2013. The Kinzua Quality Deer Cooperative: can adaptive management and local stakeholder engagement sustain reduced impact of ungulate browsers in forest systems? Boreal Environment Research 18:50-64.
12. Royo, A. A., S. L. Stout, D. S. deCalesta and T. G. Pierson. 2010. Restoring forest herb communities through landscape-level deer herd reductions: Is recovery limited by legacy effects? Biological Conservation 143:2425-2434.
13. deCalesta, D. S. 2017. Achieving and maintaining sustainable white-tailed deer density with adaptive management. Human Wildlife Interactions Journal. 11:99-111.
14. deCalesta, D. S. 1994. Impact of white‑tailed deer on songbirds within managed forests in Pennsylvania. J. Wildl. Manage. 58:711‑718.
15. McShea, W. J., and J. H. Rappole. 2000. Managing the abundance and diversity of breeding bird populations through manipulation of deer populations. Conservation Biology14: 1161-1170.
16. Royo, A. A., S. L. Stout, D. S. deCalesta, and T. G. Pierson. 2010. Restoring forest herb communities through landscape-level deer herd reductions: is recovery limited by legacy affects: Biological Conservation 143: 2425-2434.
17. Benner, M. 2007. Browsing and regeneration monitoring report for Pennsylvania’s state forests. Pennsylvania Department of conservation and natural resources. 21pp.
18. Wager, D., R. S. Seymour and D. deCalesta. 2003. Forest management and chain-of-custody 5-year recertification evaluation report for the state of Pennsylvania Department of Conservation and Natural Resources, Bureau of Forestry. Unpublished report by Scientific Certification Systems, Emeryville, California, submitted to Pennsylvania Department of Conservation and Natural Resources, Harrisburg. 125 pp.
19. Legislative Budget and Finance Committee: A Joint committee of the Pennsylvania General Assembly. 2010. Report: Examination of Current and Future Costs and Revenues from Forest Products and Oil, Gas, and Mineral Extraction on Pennsylvania Game Commission Lands.
20. deCalesta, D. S. 2017. Achieving and maintaining sustainable white-tailed deer density with adaptive management. Human Wildlife Interactions Journal 11:99-111.
21. Horsley, S. B., and D. A. Marquis. 1983. Interference by weeds and deer with Allegheny hardwood reproduction. Canadian Journal of Forest Research 13:61-69.
22. Price, W., and E. Sprague. 2012. Pennsylvania’s forests how they are changing and why we should care. Pinchot Institute for Conservation. Washington, DC.
23. Wallingford, B. D. , D. R. Diefenbach, E. S. Long, C. S. Rosenberry, and G. Alt. 2017. Biological and social outcomes of antler point restriction harvest regulations for white-tailed deer. Wildlife Monograph 196. Pages 1-26.
24. Legislative Budget and Finance Committee: A Joint committee of the Pennsylvania General Assembly. 2012. Report: Costs and Benefits of FSC Certification of DCNR Forests.
25. Wallingford, B. D. 2001. Pennsylvania Game Commission Bureau of Wildlife Management, white-tailed deer research/management. Project Code 06210.
26. Pierson, T. G., and D. S. deCalesta. 2015. Methodology for estimating deer impact on forest resources. Human Wildlife Interactions Journal 9:67-77.
27. DCNR Mission statement – http://www.dcnr.pa.gov/about/Pages/Forestry.aspx

28.Pennsylvania Bureau of Forestry Mission Statement and Objectives: http://www.docs.dcnr.pa.gov/cs/groups/public/documents/document/dcnr_20031026.pdf

Credentials for David S. deCalesta

I received MS and Ph.D. degrees in wildlife ecology from the college of Wildlife, Range, and Forest Science, Colorado State University In 1971 and 1973. My Ph.D. thesis focused on mule deer nutrition. In 1973 I was awarded the Dale and Ashby Hibbs award for outstanding contribution to big game management in Colorado based on my Ph.D. thesis. In 1998 I was recognized for my contributions to research on management of overabundant white-tailed deer populations in the Northeast by the Eastern Association of Animal Damage Professionals in the Northeast. In 2000 I was awarded the John Pearce Memorial Award for outstanding contributions and leadership on research on animal damage control and the impact of deer on forest ecosystems by the Northeastern Section of the Wildlife Society. In 2006 I was awarded the Kirkland Lifetime Achievement Award given biennially by the PA Chapter of the Wildlife Society to a professional in the wildlife discipline in mid-career to recognize outstanding achievement towards issues related to Pennsylvania wildlife.

I am a Certified Wildlife Biologist, a title bestowed by the Wildlife Society that is based on education, management, and publications in the field of wildlife management.

I have worked as a university professor in zoology, wildlife and forest ecology at North Carolina State University and Oregon State University 1973-1988 where a good part of my research and peer-reviewed scientific publications were on deer (publications list relevant to deer attached). My research focused on applied management of deer and other wildlife resources for the benefit of landowners and managers. From 1988 – 2001 I was a research wildlife biologist for the USDA Forest Service research laboratory in Warren PA where my research was focused on the impact of overabundant white-tailed deer on forest resources. From 2001 to 2012 I was a wildlife consultant providing training workshops on deer density and impact and certifying forest operations as sustainable (including management of deer impact) for the Forest Stewardship Council. At the same time I was the data manager and coordinator for deer management on the very successful Kinzua Quality Deer Cooperative in Northeast Pennsylvania where deer density was brought into balance with forest resources through public hunting by coordination, cooperation, and involvement of landowners, resource managers, scientists, and most importantly, deer hunters. Since 2013 I have been working on a book entitled Deer Management for Forest Landowners and Managers through a contract with CRC Press. Additionally, I have written invited book chapters (6) related to deer impact and deer management.

I have been an invited keynote speaker and contributor at 20+ wildlife/forestry conferences, have been a reviewer of scientific publications for wildlife and forestry journals and was an associate editor for the Wildlife Society Bulletin.

I know deer, I know their management, I know the science behind their management, and I know and respect the values and cultures of forest landowners and hunters as my entire 50 year career has been focused on deer research, deer management, and outreach to publics impacted by deer, including hunters. I am also a deer bowhunter.

Deer-related publications list for David S. deCalesta, Ph.D.:

deCalesta, D. S., Nagy, J. D., and J. A. Bailey. 1974. Some effects of starvation on mule deer rumen bacteria. J. Wildl. Manage. 38:815‑822.

deCalesta, D. S., Nagy, J. G., and J. A. Bailey. 1975. Starving and refeeding mule deer. J. Wildl. Manage. 39:663‑669.

deCalesta, D. S., Nagy, J. G., and J. A. Bailey. 1977. Experiments on starvation and recovery of mule deer does. J. Wildl. Manage. 41:81‑86.

deCalesta, D. S., and D. B. Schwendeman. 1978. Characterization of deer damage to soybeans. Wildl. Soc. Bull. 6:250‑253.

Kistner, T. P., and D. S. deCalesta. 1978. Black‑tailed deer weights. Oregon Wildl. 33:7.

deCalesta, D. S., Zemlicka, D., and L. D. Cooper. Supernumerary incisors in a black‑tailed deer. Murrelet 61:103‑104.

deCalesta, D. S. 1981. Effectiveness of control of animal damage to conifer seedlings. Pp102‑104 in S. D. Hobbs and O. G. Helgerson (eds.) Reforestation of skeletal soils. For. Res. Laboratory Workshop, Oregon State Univ. Corvallis OR. 124pp.

Sturgis, H., and D. S. deCalesta. 1981. The MacDonald Forest deer hunt: a second look. Oregon Wildl. 36:3‑8.

Matschke, G. H. , deCalesta, D. S., and J. D. Harder. 1984. Crop damage and control. Pp 647‑654 in L. K. Halls (ed.) The white‑tailed deer of North America. Stackpole Books. New York NY. 870pp.

deCalesta, D. S. 1985. Influence of regulation on deer harvest. Pp131‑138 in S. L. Beasom and S. F. Roberson (eds.) Symposium on game harvest management. Texas A & I Univ. Kingsville TX. 374pp.

deCalesta, D. S. 1985. Estimating cost‑effectiveness of controlling animal damage to conifer seedlings.  Proc. Eastern Wildl. Damage Control Conf. 2:44‑49.

deCalesta, D. S. 1986. Southwest Oregon forest mammal pests. Pages 25‑28 in O. T. Helgerson (ed.) Forest pest management in southwest Oregon. Proc. Workshop August 19‑20. Oregon State Univ. Forest Res. Lab. 88pp.

DeYoe, D. R., deCalesta, D. S., and W. Schaap. 1986. Understanding and controlling deer damage in young plantations. Oregon State Univ. Ext. Circ. 1201. 16pp.

deCalesta, D. S. 1989. Can liberal deer harvest regulations control deer damage over large areas?  Abstr.  NE  Fish and Wildl. Conf. 45:56.

deCalesta, D. S. 1989. Even‑aged forest management and wildlife populations. Pages 210‑224 in R. H. Yahner and M. Brittingham (eds.) Symposium on effects of forest management on wildlife. Pennsylvania State Univ., University Park 296pp.

deCalesta, D. S. 1990. Impacts of prescribed burning on damage by wildlife to conifer regeneration. Pages 105‑110 in Natural and prescribed fire in Pacific northwest forests. J. R. Walstad, S. R. Radosevich and D. V. Sandberg (eds). Oregon State Univ Press. Corvallis, OR, 317pp.

deCalesta, D. S. and G. W. Witmer. 1990. Drive line census for deer within fenced enclosures. USDA For. Serv. Res. Pap. NE‑643, 4pp.

deCalesta, D. S. 1991. Modification of the standard deer pellet group technique. Pennsylvania Acad. Sci. 64:187.

deCalesta, D. S. 1992.  Impact of deer on species diversity of Allegheny hardwood stands.  Proc. Northeastern Weed Sci. Soc. Abstr. 46:135.

Witmer, G. W., and D. S. deCalesta. 1992. The need and difficulty of  bringing the Pennsylvania deer herd under control.  Proc. Eastern Wildl. Damage Control Conf. 5:130‑137.

Helgerson, O. T., Newton, M., deCalesta, D. S., Schowalter, T., and E. Hanson.  1992.  Chapter 16. Protecting young regeneration.  Pp.384‑420 in Reforestation practices in southwestern Oregon and Northern California.  S. B. Hobbs, S. D. Tesch, P. W. Owston, R. E. Steward, J. C. Caprenter Jr., and G. E. Wells (eds.).  Forest Research Laboratory, Oregon State Univ. Corvallis. 465pp.

Jones, S. B., deCalesta, D. S., and S. E. Chunko. 1993.  Whitetails are changing our woodlands.  Amer. Forests. 99:20‑26.

deCalesta, D. S. 1994.  Deer and diversity in Allegheny hardwood forests: managing an unlikely challenge.  Landscape and Urban Planning 28:47‑53.

deCalesta, D. S. 1994.  Impact of white‑tailed deer on songbirds within managed forests in Pennsylvania.  J. Wildl. Manage. 58:711‑718.

Walstad, J. R., Edge, D. E., and D. S. deCalesta. 1994. Vertebrate pests of conifers in the Pacific Northwest. Video. Oregon State Univ. Corvallis OR.

deCalesta, D. S., and W. J. McShea. 1994. Impacts of white‑tailed deer on understory vegetation and faunal diversity in forest ecosystems in the eastern United States. Abstr. The Wildl. Soc. Annu. Conf. 1:22.

deCalesta. D. S. 1995. Effect of white‑tailed deer and silvicultural practices on herbs and shrubs in northern hardwood forests. Abstr. Ecol. Soc. Amer. Bull. 80:318.

McGuinness, B. and D. S. deCalesta. 1996. White-tailed deer alter diversity of songbirds and their habitat in northwestern Pennsylvania.  PA Birds (10):55-56.

deCalesta. D. S. 1997.  Deer density and ecosystems management. Pages 267‑279 in W. J. McShea (ed.). The science of overabundance: The ecology of unmanaged deer populations.  Smithsonian Inst. Press. Washington D. C.

deCalesta, D. S., and S. L. Stout. 1997. Relative deer density and sustainability: a conceptual framework for integrating deer management with ecosystem management. Wildl. Soc. Bull. 25:252‑258.

Healy, W. M., D. S. deCalesta, and S. L. Stout. 1997. A research perspective on white‑tailed deer overabundance in the northeastern United States.  Wildl. Soc. Bull. 25:259‑263

deCalesta, D. S. 1997. Deer, ecosystem damage, and sustaining forest resources.  Pages 29-37, in B. L. Gardiner (ed.). Proc. Conf. Deer as public goods and public nuisance.  Issues and policy options in Maryland. College Park.  106pp.

deCalesta, D. S. 1998. Effects of deer on forest resources: ecosystem, landscape, and management perspectives. The Wildl. Soc. Annu. Conf. 5:76.(abstr.).

Lawrence, R. K., S. L. Stout, D. S. deCalesta, W. F. Porter, and H. B. Underwood. 1998. Forest regeneration: can we overwhelm deer? The Wildl. Soc. Annu. Conf. 5:104.(abstr.).

deCalesta, D. S. 2000.  Sustained deer harvest and sustainability of ecosystem resources in Pennsylvania. The Wildl. Soc. Annu. Conf. 7:84.(abstr.).

Horsley, S.B., S.L. Stout, and D.S. deCalesta. 2003. White-tailed deer impact on the vegetation dynamics of a northern hardwood forest. Ecol. Appl. 13(1):98-118

Augustine, D. J., and D. S. deCalesta. 2003.  Defining deer overabundance and threats to forest communities from individual plants to landscape structure.  Ecoscience.  10:472-486.

Royo, A. A., S. L. Stout, D. S. deCalesta, and T. G. Pierson. 2010.  Restoring forest herb communities through landscape-level deer herd reductions: is recovery limited by legacy affects: Biological Conservation 143: 2425-2434.

2013. L. Stout, A. A Royo, D. S. deCalesta, K. McAleese, and J. C. Finley. 2013. The Kinzua Quality Deer Cooperative: can adaptive management and local stakeholder engagement sustain reduced impact of ungulate browsers in forest systems? Boreal Environment Research 18:50-64.

deCalesta, D. S. 2013. Collaboration among scientists, managers, landowners, and hunters – The Kinzua Quality Deer Cooperative.  Chapter 14 In Sands. J. P., S. J. Demaso, M. J. Schnupp, and L. A. Brennan. Wildlife Science – Connecting research with management.  CRC Press, Boca Raton FL.

deCalesta, D. S. 2013. Reliability and precision of pellet-group counts for estimating landscape -level deer density.  Human Wildlife Interactions Journal. 7:60-68.

Pierson, T. G., and D. S. deCalesta. 2015. Methodology for estimating deer impact on forest resources.  Human Wildlife Interactions Journal 9:67-77.

deCalesta, D. S., R. Latham, and K. Adams.  2016. Chapter 17 – Managing deer impacts on oak forests. In P. D. Keyser, T. Fearer, and C. A. Harper.  Managing Oak Forests in the Eastern United States. CRC Press, Boca Raton, FL.

deCalesta, D. S. 2017. Achieving and maintaining sustainable white-tailed deer density with adaptive management.   Human Wildlife Interactions Journal. 11:99-111.

deCalesta, D. S. 2017. Bridging the disconnect between agencies and forest landowners to manage deer impact. Human Wildlife Interactions Journal. 11:112-115.

deCalesta, D. S., M. Eckley, and T. G. Pierson (eds.).  Deer management for forest landowners and managers.  CRC Press.  Available spring 2019.