Supt. Don Neubacher of the Point Reyes National Seashore and park biologist Natalie Gates have been misleading the public about alternatives to the park’s current program to eradicate exotic deer. That was the word this past week from the senior vice president for wildlife of the Humane Society of the United States.

The Humane Society of the US, as well as the Marin Humane Society, Wildcare, and In Defense of Animals, has criticized the National Seashore’s eradication of non-native fallow and axis deer as cruel and unnecessary.

100_943_1.jpgThirty years ago, the Citizens Advisory Commission to the Golden Gate National Recreation Area and Point Reyes National Seashore held a series of public hearings to decide the optimum size of the two herds. Wildlife experts from around the country took part, as did hunting organizations and West Marin residents.

Commissioners, who were appointed by the US Secretary of the Interior and mostly nominated by Bay Area local governments, ultimately decided the ideal herd size was 350 deer apiece.

That quota was erratically maintained through culling until 1994 when Neubacher (right) became superintendent and stopped the culling. At that point, the fallow herd in particular began growing.

In 2002, the citizens’ commission expired, and when the Neubacher Administration decided to eradicate the deer, no public hearings were held. When a public meeting was finally held, the public had to content itself with listening to panelists picked by the park. By way of avoiding a general discussion that might have worked out compromise acceptable to most of the public, the park divided the crowd into focus groups — with opposition to slaughtering deer treated primarily as a marketing problem.

The fallow deer, native to the Near East, and the axis deer, native to South Asia, have been on Point Reyes since 1948. The park opened in 1965.

Citing the herds’ growth and their ancestors’ having been non-native, the Neubacher Administration in recent months has been attempting to eradicate all 1,000 to 1,200 of the deer.

About 180, including only a handful of axis deer (as seen in photo below by Trish Carney), still survive.

2082275718_842210215e_m.jpgAnimal-rights groups have urged the National Park Service to manage the herds’ sizes with contraception.

The Neubacher Administration has responded that the hunting company it has hired hasn’t been having much success with the contraceptive it’s using, GonaCon.

National Seashore officials made misleading statements in dismissing the effectiveness of the contraceptive, PZP, used to manage herds at other parks, the Humane Society notes.

Here are the Humane Society’s “clarifications and explanations of recent public claims made by [biologist] Natalie Gates and [Supt. Don] Neubacher at Point Reyes National Seashore.”

92x133_grandy_john.jpgBy John Grandy, PhD, Senior Vice President (right), The Humane Society of the United States

1. With regard to the PZP contraceptive [supposedly being] outdated and less advanced:

PZP is fully tested and completely safe with the adjuvants [pharmacological agents added to a drug to increase its effect] and techniques I recommend in my report, as the numerous peer-reviewed papers I cite demonstrate conclusively. These studies have been conducted over more than 15 years and have included all phases of the reproductive cycle.

There is no comparable data for GonaCon [the deer contraceptive used by the hunting company hired by the park, White Buffalo]. There is no published peer reviewed literature regarding the safety and efficacy of GonaCon and the adjuvants used with it. And there are numerous anecdotal reports of death and/or abscesses or ulcerous lesions in animals treated with GonaCon and its adjuvant.

True, PZP has been in use longer, but the safety and reliability are proven without question.


Surviving fallow deer. Ear tags show that two of the does have received contraception. (Fallow deer photos by Ella Walker)

2. With regard to Natalie Gates’ comment the [Humane Society’s] White Paper approach would not be effective and that it is not practical to use only contraception to eliminate all non-native deer.

These are simply self-serving rephrasings of material in my report that allow her to give the answer she wants people to hear. The paper does not suggest that all deer in the park can be eliminated using the PZP contraceptive. In fact, it clearly states exactly the opposite. What it does suggest and indeed proves with peer-reviewed literature is that a deer population as small as the one that now exists (~)180 can be conscientiously and effectively managed to meet the National Park Service’s biological objectives for vegetation in the Point Reyes National Seashore with PZP.

3. With regard to the cost of the PZP contraceptive versus GonaCon: We do not know what GonaCon costs. I summarized the cost of PZP based on peer-reviewed literature and our direct experience, as follows:

The PZP vaccine and darts are relatively inexpensive; actually less than $50 per treatment (primer dose at $21 plus booster does at $21 plus two darts at $3; and that is only for the first year. Thereafter the cost is about $25 per year). The primary cost in such programs is labor to administer the vaccine (Rutberg 2005).

sweetestmay-5.jpgAt Fire Island National Seashore, where deer were accessible and capture for tagging [right, as is being done in the Point Reyes National Seashore] was not necessary, treatments took 1.4 hours per deer (Naugle et al. 2002). At another site, contraceptive darting took 1.6 hours per deer (Rutberrt et al. 2004).

The [National Seashore’s] environmental-impact statement assumes six hours per inoculation (p. 37). Even at six hours per doe, treatment of 80 does would take 60 person-days per year (citations in my report).

Frankly, the National Park Service estimate of the cost of PZP vaccination is based on nothing but speculation and is grossly inaccurate, as this peer-reviewed information shows.

4. With regard to statements from [regional Park Service director Jon] Jarvis and [National Seashore Supt.] Neubacher regarding the need to kill a few deer as part of a contraceptive program.

It may be necessary to euthanize one or more of the deer currently treated with GonaCon if their reported symptoms are causing such pain and suffering that this is the only alternative. If deer are treated with the PZP contraceptive, there is no need to kill, immobilize or tag these deer if the protocol used successfully with white-tailed deer at Fire Island National Seashore is followed.

5. With regard to Neubacher’s claim that he is simply following federal legislation.

It is, of course, true that Neubacher is acting under his interpretation of the broad authority of the enabling legislation and subsequent amendments for Point Reyes National Seashore even as he attempts to eliminate the deer. It is surprising, at the least, that axis and fallow deer were not designated a cultural and historic resource at the time the National Seashore was created. Indeed, numerous reports of past activities at the National Seashore, as well as annual reports, suggest that they were often treated as such, even if they were not so designated.

However, to remove any ambiguity regarding their importance as a cultural and historic resource for the park and environs, we suggest including a rider such as I suggested in my report (Page 12) to designate fallow and axis deer a cultural and historic resource for the Point Reyes National Seashore and require that they be managed as such.

This approach has been successfully followed in Assateague Island National Seashore and Cape Lookout National Seashore.