This is the html version of the file http://www.aphis.usda.gov/ws/nepa/ILdeerFONSI.pdf.
G o o g l e automatically generates html versions of documents as we crawl the web.
To link to or bookmark this page, use the following url: http://www.google.com/search?q=cache:PmxZujRnu8sJ:www.aphis.usda.gov/ws/nepa/ILdeerFONSI.pdf+urban+deer+non-lethal&hl=en&ct=clnk&cd=12&gl=ca


Google is neither affiliated with the authors of this page nor responsible for its content.
These search terms have been highlighted:  urban  deer  non  lethal  nonlethal 

Page 1
1
USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Animal Damage Control
(ADC). 1997 (revised). Animal Damage Control Program, Final Environmental Impact Statement. Anim. Plant Health Inspection
Serv., Anim. Damage Control, Operational Support Staff, 4700 River Road, Unit 87, Riverdale, MD 20737. Volume 1, 2 & 3.
DECISION
AND
FINDING OF NO SIGNIFICANT IMPACT
An Integrated Wildlife Damage Management Approach
for the Management of White-tailed Deer Damage
In the State of Illinois
The U.S. Department of Agriculture, Animal and Plant Health Inspection Service (USDA-APHIS),
Wildlife Services (WS) program responds to requests for assistance from individuals, organizations and
agencies experiencing damage caused by wildlife in Illinois. WS cooperates with land and wildlife
management agencies to reduce wildlife damage effectively and efficiently according to applicable
federal, State and local laws and Memorandums of Understanding (MOUs) between WS and other
agencies. Ordinarily, according to APHIS procedures implementing the National Environmental Policy
Act (NEPA), individual wildlife damage management actions may be categorically excluded (7 CFR
372.5(c), 60 Fed. Reg. 6000-6003, 1995). To evaluate and determine if any potentially significant
impacts to the human environment from WS planned and proposed program would occur; to facilitate
planning, interagency coordination, and the streamlining of program management; and to clearly
communicate with the public the analysis of cumulative impacts an environmental assessment (EA) was
prepared. The EA documents the need for
a
white-tailed deer (Odocoileus virginians) damage
management program to alleviate damage to agriculture, property, natural resources, and human health
and safety on public and private lands in Illinois and assessed potential impacts of various alternatives
for responding to requests for assistance. Comments from the public involvement process were
reviewed for substantial issues and alternatives which were considered in developing this decision. The
EA is tiered to the programmatic Environmental Impact Statement (EIS) for the Wildlife Services
Program
1
(USDA 1997).
WS proposed action is to implement an Integrated Wildlife Damage Management (IWDM) program
on all land classes in Illinois that would include lethal and nonlethal direct control and technical
assistance to reduce damage to property, agricultural and natural resources, and human health and
safety caused by white-tailed deer. Direct control assistance will only take place after a request for
services has been received and where permission has been granted by the landowner or land manger.
Based on the analysis in the EA, I have determined that there will not be a significant impact,
individually or cumulatively, on the quality of the human environment from implementing the proposed
action, and that the action does not constitute a major federal action significantly affecting the quality
of the human environment.
Public Involvement
The pre-decisional EA was released to the public for a 30 day comment period with a legal notice

Page 2
Deer Damage Management in IL [Page 2 of 8]
being placed in two newspapers (Chicago Tribune [Chicago, IL] and The State Journal-Register
[Springfield, IL]) encompassing the affected area. The pre-decisional EA was also mailed directly to
agencies, organizations and individuals with probable interest in the proposed program. All comments
were analyzed to identify substantial new issues, alternatives, or to redirect the program. Two
comment letters and one phone call were received by WS within the 30 day comment period. The
letters and phone call were from the IL Department of Natural Resources (IDNR), the US Fish and
Wildlife Service, and the Department of Energy’s Argonne National Laboratory, respectively,
providing their support of the proposed program.
The letters and record of phone conversation are maintained in the administrative file located at the
Illinois WS State Office, 2869 Via Verde Drive, Springfield, IL 62703-4325.
Monitoring
The Illinois WS program will review the EA each year to ensure that it and the analysis are sufficient.
This EA would remain valid until Illinois WS and other appropriate agencies determine that new needs
for action, changed conditions or new alternatives having different environmental effects must be
analyzed. At that time, this analysis and document would be supplemented pursuant to NEPA.
Major Issues
Several issues were contained in the scope of this EA. These issues were consolidated into the
following five primary issues to be considered in detail:
• Effects on white-tailed deer populations;
• Effects on plants and other wildlife species, including threatened and endangered species;
• Effects on human health and safety;
• Humaneness of methods to be used;
• Effects on aesthetic values; and
• Effects on regulated white-tailed deer hunting.
Alternatives Analyzed in Detail
Four potential Alternatives were developed to address the issues identified above. A detailed
discussion of the anticipated effects of the Alternatives on the issues are contained in the EA. The
following summary provides a brief description of each Alternative and its anticipated impacts.
Alternative 1. Integrated Deer Damage Management Program (Proposed Action/No
Action).
Under this alternative, Wildlife Services would continue the current program that administers
an Integrated Wildlife Damage Management (IWDM) approach to alleviate white-tailed deer
damage to agriculture, property, natural resources, and human health and safety in Illinois. An
IWDM approach would be implemented on all private and public lands of Illinois where a need
exists, a request is received, and funding is available. An IWDM strategy would be

Page 3
Deer Damage Management in IL [Page 3 of 8]
recommended and used, encompassing the use of practical and effective methods of preventing
or reducing damage while minimizing harmful effects of damage management measures on
humans, other species, and the environment. Under this action, WS would provide technical
assistance and operational damage management, including non-lethal and lethal management
methods by applying the WS Decision Model (Slate et al. 1992). When appropriate, habitat
modifications, harassment, repellants, and physical exclusion could be recommended and
utilized to reduce deer damage. In other situations, deer would be removed as humanely as
possible by sharpshooting or live capture followed by euthanasia under permits issued by the
IDNR. In determining the damage management strategy, preference would be given to
practical and effective non-lethal methods. However, non-lethal methods may not always be
applied as a first response to each damage problem. The most appropriate response could
often be a combination of non-lethal and lethal methods, or there could be instances where
application of lethal methods alone would be the most appropriate strategy. Appendix B of the
EA describes the methods available for recommendation and use by WS under this alternative.
Deer damage management would be conducted in the State, when requested, on private or
public property after an Agreement for Control or other comparable document has been
completed. All deer damage management would be consistent with other uses of the area and
would comply with appropriate federal, State, and local laws.
Alternative 2. Non-lethal Deer Damage Management only by WS.
This alternative would require WS to use and recommend non-lethal methods only to resolve
all deer damage problems. Requests for information regarding lethal management approaches
would be referred to IDNR, local animal control agencies, or private businesses or
organizations. Persons receiving deer damage could still resort to lethal methods or other
methods not recommended by WS, use contractual services of private businesses that were
available to them, or take no action. Appendix B of the EA describes a number of non-lethal
methods available for recommendation and use by WS under this alternative.
Alternative 3. Lethal Deer Damage Management only by WS.
This alternative would require WS to use and recommend lethal methods only to resolve all
deer damage problems. Requests for information regarding non-lethal management approaches
would be referred to IDNR, local animal control agencies, or private businesses or
organizations. Individuals might choose to implement WS lethal recommendations, implement
non-lethal methods or other methods not recommended by WS, contract for WS lethal direct
control services, use contractual services of private businesses, or take no action. Appendix B
of the EA describes lethal methods available for recommendation and use by WS under this
alternative.
Alternative 4. No Deer Damage Management by WS.
This alternative would eliminate WS involvement in all deer damage management activities.
WS would not provide direct operational or technical assistance. Persons requesting assistance
from WS would have to conduct their own deer damage management without WS input. All

Page 4
Deer Damage Management in IL [Page 4 of 8]
requests for white-tailed deer damage management would be referred to the IDNR, local
animal control agencies or private individuals, businesses or organizations. Assistance may or
may not be available from any of these entities.
Alternatives Considered but not Analyzed in Detail
Two alternatives were considered, but not analyzed in detail. These include the following.
Live Trap and Relocation.
Under this alternative WS would capture deer alive using cage-type live traps or capture drugs
administrated by dart gun and then relocate the captured deer to another area. Numerous
studies have shown that live-capture and relocation of deer is relatively expensive, time-
consuming, and inefficient (Ishmael and Rongstad 1984, O’Bryan and McCullough 1985, Diehl
1988, Jones and Witham 1990, Ishmael et al. 1995). Population reduction achieved through
capture and relocation is labor intensive and would be costly ($273-$2,876/deer) (O’Bryan and
McCullough 1985, Bryant and Ishmael 1991). Additionally, relocation frequently results in
high mortality rates for deer (Cromwell et. al. 1999, O’Bryan and McCullough 1985, Jones and
Witham 1990, Ishmael et. al. 1995). Deer frequently experience physiological trauma during
capture and transportation, (capture myopathy) and deer mortality after relocation, from a wide
range of causes within the first year, has ranged from 25-89% (Jones and Witham 1990, Mayer
et al. 1993). O’Bryan and McCullough (1985) found that only 15% of radio-collared black-
tailed deer that were live-captured and relocated from Angel Island, California, survived for
one year after relocation. Although relocated deer usually do not return to their location of
capture, some do settle in familiar suburban habitats and create nuisance problems for those
communities (Bryant and Ishmael 1991). High mortality rates of relocated deer, combined with
the manner in which many of these animals die, make it difficult to justify relocation as a
humane alternative to lethal removal methods (Bryant and Ishmael 1991). Chemical capture
methods require specialized training and skill. A primary limitation of darting, the limited range
at which deer can be effectively hit, is generally less than 40 yards. With modern scoped rifles,
however, a skilled sharpshooter can hit the head or neck of a deer for a quick kill out to 200
yards and beyond. Thus, chemical capture is far less efficient, more labor intensive, and much
more costly than lethal removal with rifles. Translocation of wildlife is also discouraged by WS
policy (WS Directive 2.501) because of stress to the relocated animal, poor survival rates,
potential for disease transfer, and difficulties in adapting to new locations or habitats.
Population Stabilization Through Birth Control.
Deer would be sterilized or contraceptives administered to limit the ability of deer to produce
offspring. Contraceptive measures for deer can be grouped into four categories: surgical
sterilization, oral contraception, hormone implantation, and immunocontraception (the use of
contraceptive vaccines). Sterilization could be accomplished through surgical sterilization
(vasectomy, castration, and tubal ligation), chemosterilization, and gene therapy.
Contraception could be accomplished through hormone implantation (synthetic steroids such as
progestins), immunocontraception (contraceptive vaccines), and oral contraception (progestin

Page 5
Deer Damage Management in IL [Page 5 of 8]
administered daily). These techniques would require that deer receive either single, multiple, or
possibly daily treatment to successfully prevent conception.
Use and effectiveness of reproductive control as a wildlife population management tool is
limited by population dynamic characteristics (longevity, age at onset of reproduction,
population size and biological/cultural carrying capacity, etc.), habitat and environmental
factors (isolation of target population, cover types, and access to target individuals, etc.),
socioeconomic and other factors. Population modeling indicates that reproductive control is
more efficient than lethal control only for some rodent and small bird species with high
reproductive rates and low survival rates (Dolbeer 1998). Additionally, the need to treat a
sufficiently large number of target animals, multiple treatments, and population dynamics of
free-ranging populations place considerable logistic and economic constraints on the adoption
of reproduction control technologies as a wildlife management tool for some species. Research
into reproductive control technologies, however, has been ongoing, and the approach will
probably be considered in an increasing variety of wildlife management situations.
The use of this method would be subject to approval by federal and State Agencies. This
alternative was not considered in detail because:
It would take a number of years of implementation before the deer population would
decline and therefore, damage would continue at the present unacceptable level for a
number of years.
Surgical sterilization would have to be conducted by licensed veterinarians, and would
therefore be extremely expensive.
It is difficult, time-consuming, and expensive to effectively live trap, chemically capture,
or remotely treat the number of deer necessary to effect an eventual decline in the
population.
State and federal regulatory authorities have approved no chemical or biological agents
for deer contraception for use.
Finding of No Significant Impact
The analysis in the EA indicates that there will not be a significant impact, individually or cumulatively,
on the quality of the human environment as a result of this proposed action. I agree with this
conclusion and therefore find that an EIS need not be prepared. This determination is based on the
following factors:
1.
White-tailed deer damage management, as conducted by WS in Illinois, is not regional or
national in scope.
2.
Based on the analysis documented in the EA, the impacts of the proposed action will not
significantly affect public health or safety. Risks to the public from WS methods were
determined to be low in a formal risk assessment (USDA1997, Appendix P).
3.
There are no unique characteristics such as park lands, prime farm lands, wetlands, wild and

Page 6
Deer Damage Management in IL [Page 6 of 8]
scenic areas, or ecologically critical areas that would be significantly affected by the proposed
action. Built-in mitigation measures that are part of WS standard operating procedures and
adherence to laws and regulations will further ensure that WS activities do not harm the
environment.
4.
The effects on the quality of the human environment are not highly controversial. Although
there is some opposition to wildlife damage management, this action is not highly controversial
in terms of size, nature or effect.
5.
Mitigation measures adopted and/or described as part of the proposed action minimize risks to
the public, prevent adverse effects on the human environment and reduce uncertainty and risks.
The effects of the proposed activities are known and are not highly uncertain and do not
involve unique or unknown risks.
6.
The proposed action does not establish a precedent for future actions with significant effects.
7.
No significant cumulative effects were identified through this assessment. The number of
white-tailed deer killed by WS, when added to the total known other take does not significantly
effect white-tailed deer populations.
8.
The proposed activities would not affect districts, sites, highways, structures or objects listed in
or eligible for listing in the National Register of Historic Places, nor would they likely cause any
loss or destruction of significant scientific, cultural or historical resources. Deer damage
management would not disturb soils or any structures and, therefore, would not be considered
a “Federal undertaking” as defined by the National Historic Preservation Act.
9.
WS has determined that the proposed action would not adversely affect any federal or Illinois
state listed threatened or endangered species.
10.
The proposed action would be in compliance with all federal, State and local laws imposed for
the protection of the environment.
Decision and Rationale
I have carefully reviewed the EA and the input from the public involvement process. I believe that the
issues identified in the EA are best addressed by selecting Alternative 1- Integrated Deer Damage
Management Program (Proposed Action/No Action) and applying the associated mitigation and
monitoring measures discussed in Chapter 3 of the EA. Alternative 1 is selected because (1) it offers
the greatest chance at maximizing effectiveness and benefits to resource owners and managers while
minimizing cumulative impacts on the quality of the human environment that might result from the
program’s effect on target and non-target species populations; (2) it presents the greatest chance of
maximizing net benefits while minimizing adverse impacts to public health and safety; and (3) it offers a
balanced approach to the issues of humaneness and aesthetics when all facets of these issues are
considered. The comments identified from public involvement were minor and did not change the
analysis. Therefore, it is my decision to implement the proposed action as described in the EA. For

Page 7
Deer Damage Management in IL [Page 7 of 8]
additional information regarding this decision, please contact Kirk E. Gustad, State Director, Illinois
WS State Office, 2869 Via Verde Drive, Springfield, IL 62703-4325, telephone (217) 241-6700.
/s/
10/30/02
Charles S. Brown
Date
Acting Regional Director
APHIS-WS Eastern Region

Page 8
Deer Damage Management in IL [Page 8 of 8]
Literature Cited:
Bryant, B. K. and W. Ishmael. 1991. Movement and mortality patterns of resident and translocated
suburban white-tailed deer. Pages 53-58 in L. W. Adams and D. L. Leedy, eds. Wildlife
conservation in metropolitan environments. Natl. Inst. Urban Wildl. Symp. Ser. 2, Columbia,
MD.
Cromwell, J. A., R. J. Warren, and D. W. Henderson. 1999. Live-capture and small-scale relocation
of urban deer on Hilton Head Island, South Carolina. Wildl. Soc. Bull. 23:1025-1031.
Diehl, S. R. 1988. The translocation of urban white-tailed deer. Pages 238-249 in L. Nielsen and R.
D. Brown, editors. Translocation of wild animals. Wisconsin Humane Society, Inc.,
Milwaukee, and Caesar Kleberg Wjildlife Research Institute, Kingsville, TX.
Dolbeer, R. A. 1988. Population dynamics: the foundation of wildlife damage management for the
21
st
century. Pp. 2-11 in Proc. 18
th
Vertebr. Pest Conf., Davis, CA.
Ishmael, W. E., D. E. Katsma, T. A. Isaac, and B. K. Bryant. 1995. Live-capture and translocation of
suburban white-tailed deer in River Hills, Wisconsin. Pages 87-96 in J. B. McAninch, editor.
Urban deer: a manageable resource? Proceedings 1993 symposium, North Central Section,
The Wildlife Society, 12-14 December 1993, St. Louis, Missouri.
Ishmael, W. E. and O. J. Rongstad. 1984. Economics of an urban deer-removal program. Wildl. Soc.
Bull. 12:394-398.
Jones, J. M. and J. H. Witham. 1990. Post-translocation survival and movements of metropolitan
white-tailed deer. Wildl. Soc. Bull. 18:434-441.
Mayer, K. E., J. E. DiDonato, and D. R. McCullough. 1993. California urban deer management: Two
case studies. pp.17-18 in: Urban Deer Symposium. St. Louis, MO 54 pp.
O’Bryan, M. K., and D. R. McCullough. 1985. Survival of black-tailed deer following relocation in
California. J. Wildl. Manage. 49:115-119.
Slate, D. A., R. Owens, G. Connolly and G. Simmons. 1992. Decision making for wildlife damage
management. Trans. North Am. Wildl. Nat. Res. Conf. 57:51-62.
USDA U.S. Department of Agriculture). Animal and Plant Health Inspection Service (APHIS), Animal
Damage Control (ADC). 1997. Final Environmental Impact Statement. USDA, APHIS, ADC
Operational Support Staff, 4700 River Road, Unit 87, Riverdale, MD 20737.