Non-Native Deer Management Plan

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In its 2001 Management Policies, the National Park Service instructs parks such as Point Reyes National Seashore to "re-establish natural functions and processes in human-disturbed components of natural systems." The Management Policies include non-native species as an example of a human-caused disturbance that can have severe impacts on natural biota and ecosystems.

Parks are specifically mandated to control exotic species "up to and including eradication" of a population if that species does not meet an identified park purpose and if such control is "prudent and feasible." Only through the removal of exotics and other changes resulting from human disturbance can the National Park Service return its park units to the most natural condition possible and meet its mandate to preserve them in this condition for future generations.

The presence of non-native axis and fallow deer is both the result of human activities and disruptive to many elements of the natural ecosystem at Point Reyes National Seashore. Some of the more serious effects these non-native deer have at the Seashore include possible competition with and displacement of native tule elk and black-tailed deer (particularly in high deer density or low forage conditions), the potential for transmitting disease to these native ungulates, and heavy use of and resulting impacts to riparian habitat and presumably to the native wildlife dependent on this habitat. Fallow deer are known to cause reduction or local extinctions of small mammals that rely on the same ground-level grasses and forbs. Both axis and fallow deer browse shrubs when grasses are not available, and alter riparian cover and vegetation through browsing and creating trails. Loss of riparian habitat can affect a number of species at Point Reyes National Seashore, including several special status species, such as California red-legged frog, Coho salmon and steelhead trout. Fallow and axis deer also affect Seashore ranchers by damaging fences, and through depredation of livestock pastures and supplemental livestock feed.

Populations of both species of deer have increased in recent years and the range of fallow deer appears to be expanding eastward, towards and beyond Seashore boundaries. This population and range expansion, if allowed to continue, could mean these same types of impacts would occur on private and public lands outside of Point Reyes National Seashore. In late 2005, the population of axis deer and fallow deer was estimated to be about 250 and 860, respectively.

The purpose of the Non-Native Deer Management Plan is to define management prescriptions for non-native deer management. Both the park's General Management Plan and Resource Management Plan, identify goals for management of these exotic species. The park RMP (NPS 1999) indicates that: "Regardless of potential competition and disease issues, the presence of these nonnative deer compromises the ecological integrity of the Seashore and the attempts to reestablish the native cervid fauna comprising tule elk and black-tailed deer" and notes that three scientific panels comprised of federal, state, and university researchers and managers recommended the removal of non-native deer to promote native deer and elk.

The objectives of the plan are:

  • To correct past and ongoing disturbances to Seashore ecosystems from introduced nonnative ungulates and thereby to contribute substantially to the restoration of naturally functioning native ecosystems.
  • To minimize long-term impacts, in terms of reduced staff time and resources, to resource protection programs at the Seashore, incurred by continued monitoring and management of non-native ungulates.
  • To prevent spread of populations of both species of non-native deer beyond Point Reyes National Seashore and Golden Gate National Recreation Area boundaries.
  • To reduce impacts of non-native ungulates to agricultural permittees within pastoral areas through direct consumption of forage, transmission of disease to livestock and damage to fencing.

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Axis Deer herd
A herd of non-native Axis deer

Final Non-Native Deer Management Plan & Environmental Impact Statement

This Final Non-Native Deer Management Plan & Environmental Impact Statement analyzes a preferred alternative, no action, and four additional alternatives for future management of Axis deer (Axis axis) and Fallow deer (Dama dama) in Point Reyes National Seashore and Golden Gate National Recreation Area lands administered by Point Reyes National Seashore. As lead agency for the plan, the National Park Service developed the alternatives to address problems and management concerns of non-native deer in Point Reyes National Seashore. The management plan would assist the National Park Service in the restoration of native ecosystems within the park, prevent spread of non-native deer into surrounding private and public lands, and address adverse impacts to agricultural permittees within the Point Reyes National Seashore.

The alternatives differ primarily in their approach to deer population control and in desired future numbers of deer. Alternative A, the No Action alternative, calls for no change in existing management of non-native deer, and results in increased range and numbers of both species. Alternatives B and C call for controlling numbers of both species at a pre-determined level (i.e., 350 axis and 350 fallow deer) using lethal removal alone or a combination of lethal removal and long-acting contraceptives. Alternative D calls for complete removal of both species by 2021 using lethal removal alone. Alternative E is the preferred alternative and would completely remove both species of non-native deer from the Seashore by 2021 using a combination of long-acting contraceptives and lethal removal. Issues raised during public scoping were incorporated in the analysis and are discussed in the document. A number of alternatives calling for relocation, fencing, hunting, and contraception alone are discussed as Considered but Rejected.

Environmental consequences of the five alternatives are divided into the impact topics of natural resources (water, soils, vegetation, wildlife, and special status species), human health and safety, visitor experience, park operations, and regional economy. Impacts to areas outside the park are discussed as they might be affected by dispersing or expanding non-native deer populations.

Responses to comments submitted to the Seashore during the 63-day public comment period (from February 4, 2005, through April 8, 2005) are included in Chapter 5. Additional detail was added to the EIS concerning issues that engendered the most frequent comments. Updated scientific information, relating to impacts of non-native deer to PRNS natural resources, can be found in Chapter 3, Affected Environment, as well in the impact sections for each alternative.

The Record of Decision adopting the alternative or actions constituting the approved plan was signed on October 17, 2006, by John Jarvis, Regional Director, Pacific West Region. The Notice of Approval of Record of Decision was published in the Federal Register on November 28, 2006.

The complete FEIS is posted below. The printed document and digital version on compact disk will also be available for viewing at the park headquarters and local libraries. For further information on the FEIS, please check this website or contact Seashore headquarters at 415-464-5100.


Final Non-Native Deer Management Plan & Environmental Impact Statement (17,329 KB PDF)

Errata, October 1, 2006 (10 KB PDF)

Correspondence Identification Index (398 KB PDF)
This alphabetized index matches each commenter with a Correspondence ID number, a unique identifier for the letter, email or fax submitted by each individual or organization.

Topic Codes Index (84 KB PDF)
This index matches Correspondence ID numbers to one or more Topic Codes. Several Topic Codes are listed after a Correspondence ID if the commenter included more than one substantive comment in his/her letter. Topic Codes, each with its corresponding NPS response, maybe found on pages 302 to 334 of the Final Non-Native Deer Management Plan & Environmental Impact Statement. Note: Commenters whose Correspondence ID is assigned Topic Codes AL 4200 or AL 5000 will find the NPS response to their comments under AL 2000 (p. 309) and WH 1100 (p. 329), respectively.

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Draft Non-Native Deer Management Plan & Environmental Impact Statement

The Non-Native Deer Management Plan Draft Environmental Impact Statement analyzed a preferred alternative, no action, and four additional alternatives for future management of Axis deer (Axis axis) and Fallow deer (Dama dama) in Point Reyes National Seashore and Golden Gate National Recreation Area lands administered by Point Reyes National Seashore. As lead agency for the plan, the National Park Service developed the alternatives to address problems and management concerns relating to non-native deer in the Seashore. The management plan will assist National Park Service in the restoration of native ecosystems within the park, will prevent spread of non-native deer into surrounding private and public lands, and will address adverse impacts to agricultural permittees within the Seashore.
Draft Non-Native Deer Management Plan & Environmental Impact Statement - December 2004 (1,795 KB PDF)


Humane Society of the U.S. Report: "Strategies to Manage Axis and Fallow Deer,"

In May of 2008, Point Reyes National Seashore received a report prepared by the Humane Society of the U.S. (HSUS) entitled "Strategies to Manage Axis and Fallow Deer at Pt. Reyes National Seashore and Environs, Including a Proposal to Designate such Deer a Cultural and Historic Resource at PRNS." After careful review, an analysis of the HSUS report was prepared by Seashore biologists and cultural resource managers. They evaluated the report's technical soundness as well as the feasibility of the recommendations. Many of the reports proposals were discussed at length in the park's Non-Native Deer Management Plan/Environmental Impact Statement, released in 2006.

Two-page Summary of Point Reyes National Seashore's Natural and Cultural Resources Management Divisions' Analysis of the Humane Society of the U.S. Report, "Strategies to Manage Axis and Fallow Deer," June 26, 2008 (20 KB PDF)


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Frequently Asked Questions

Updated: June 2008

The park is managing non-native deer with a combination of an experimental contraceptive treatment and lethal removal in order to eventually remove all non-native deer over the next sixteen to twenty years. The Seashore began implementing the plan in the summer of 2007. As animals are removed, meat will be donated to local charities and to the California Condor Recovery Program. Wildlife professionals, trained specifically in capturing and removing animals in a quick and humane manner, will carry out the work.
Park scientists have found that the non-native deer have several serious impacts on Seashore ecosystems. The most important of these impacts can be summed in the following ways:
  1. There is increased competition with native tule elk and black-tailed deer for certain types of food. Both axis and fallow deer have been shown to adapt their feeding habits during droughts or times of low forage availability, to the same foods that native black-tailed deer use exclusively and year-round. Deer eat upwards of 3–4% of their body weight in forage each day. Consequently, one to two tons of forage is being removed by non-native deer every day and is no longer available to native deer and other native species. Forage in the Seashore is limited and increased competition will negatively impact black-tailed deer populations.
  2. Non-native deer have been shown to carry non-native organisms known to cause fatal disease in both tule elk and black-tailed deer (e.g. paratuberculosis and pediculosis). Paratuberculosis, a wasting diarrheal disease of ungulates, has been diagnosed in 8%–9% of axis and fallow deer. In 2005, USDA researchers discovered a species of exotic louse in Seashore fallow deer which has been documented to cause fatalities in northern California and Washington black-tailed deer.
  3. During the fall mating season, or rut, male fallow deer establish areas known as “leks” near streams or in oak woodlands, where they display to potential mates. This behavior is unique amongst deer, but it is similar to breeding systems used by grouse. A fallow deer lek typically includes males displaying in an area of about 100–150 square meters. Using its hooves and antlers, each male clears away most or all of the vegetation and digs a pit up to 0.6 meters deep which he defends throughout the breeding season. The damage caused resembles feral pig damage but with more soil compaction than upheaval. Leks cause damage to soils, water resources, and vegetation. They indirectly harm the species which depend on these habitats. Damage near waterways can impact federally endangered and threatened species such as Coho salmon and California red-legged frogs.
The Seashore's management plan is the result of five years of consultation with the public, biologists and contraception experts nationwide. The 431-page Environmental Impact Statement (EIS), entitled Point Reyes National Seashore Non-Native Management Plan: Protecting the Seashore's Native Ecosystems, carefully analyzed a range of action alternatives, ranging from no action to removing all non-native deer from the park. This document is available online at: https://www.nps.gov/pore/learn/management/upload/planning_nonnativedeermanagementplan_final_2006.pdf.

The public input process for the plan consisted of a two-month public "scoping" period in 2002 to raise issues to be considered in the plan, and, a two-month public comment period for review of the draft plan in 2005. During the comment period, the NPS received 1,980 pieces of correspondence (including letters, emails, facsimiles and hand-delivered comment forms). All comments were reviewed and carefully considered.
Fallow deer (Dama dama) are native to Asia Minor while axis deer (Axis axis) originate from India. In the 1940s and 1950s (before authorization of the Seashore in 1962), a local landowner bought surplus axis and fallow deer from the San Francisco Zoo and released them on the western slope of Mount Vision for hunting purposes. Their numbers increased until they reached an estimated total of 900–1100 deer in 2002.
The NPS has consulted with leading experts in wildlife contraception across the U.S. and the overwhelming consensus is that contraception alone would not control non-native deer in the Seashore. There are too many deer and they are too difficult to access. They occupy at least 50,000 acres, much of which is in wilderness, without road or trail access. In the past, wildlife contraceptives have not lasted more than a year and have required annual "boosters", via dartguns, to remain effective. As Seashore biologists learned in a six-year contraceptive trial with tule elk (from 1994 to 2000), wild deer learn to avoid being re-treated and each booster becomes increasingly more difficult over the ten to twenty year life of a deer. Currently, contraception as a standalone population control method for deer is only practical in small, enclosed populations such as those found on some small islands or in zoos.
A number of alternatives for controlling the ecological impacts of non-native deer were considered by the park but dismissed because they were not feasible. One of these alternatives was to relocate deer outside of the Seashore on the lands of willing private or public owners. Paratuberculosis, or Johne's disease, and the presence of exotic lice have been documented in Point Reyes non-native deer. Johne's disease is a chronic, incurable and transmissible diarrheal disease of domestic and wild ruminants. Carriers can shed the organism sporadically and Johne's disease can be difficult to diagnose in infected deer. The non-native lice found on non-native deer at PRNS have been shown to cause death in native black-tailed deer in the Pacific Northwest. Because of the difficulty of accurately screening deer for Johne’s disease or lice, and the infection risk that carrier animals would pose to livestock, farmed deer, and other wildlife, California Department of Fish and Game has communicated to NPS that movement of non- native deer to other parts of the state is undesirable.
Current wildlife contraceptive technology is not advanced to the point where effective contraceptives are commercially available. The Seashore, in cooperation with researchers in the US Department of Agriculture, is currently testing an experimental drug with the potential for multiple-year effectiveness on eighty fallow deer females. This drug, GonaCon™, is a vaccine which, when injected into the hind leg of a female deer, renders the animal immune to one of the naturally produced hormones required for pregnancy. Previous studies on GonaCon™ trials with another species of deer indicate that the drug may prevent pregnancy for up to four years with just one treatment. Because the drug is a protein, it is broken down in the digestive tracts of scavengers and therefore there are no impacts to other animals in the food chain. In the summer of 2007, Park Service and contractor staff treated fallow deer that were captured under drop nets or with sedative darts. The park's GonaCon™ project is one of the largest contraceptive trials on free-ranging deer in the U.S.
Yes. U.S. Geological Survey scientists believe that, based on overlap between the foods that native and non-native deer eat, for every two to three nonnative deer, we are losing one native deer. At current levels of non-native deer, there is a 46% reduction in black-tailed deer population. Additionally, the non-native deer have been shown to carry diseases known to be fatal for tule elk and black-tailed deer (paratuberculosis, a diarrheal wasting disease, and pediculosis, infection with an exotic louse).
As of February 2008, approximately eighty fallow deer have been treated with contraceptives, and approximately 150 axis deer and 520 fallow deer have been culled.
Over 75% of culled deer have been donated to food banks, soup kitchens, Native American tribes, or California Condor restoration programs throughout the state.
The contractor's capture and culling operations are continuously observed by NPS staff and have been found to be, without exception, safe and humane. The contractor has years of experience in humane capture and culling of wildlife in suburban and urban areas where safety is a predominant concern. The NPS contract specifies that the contractor will comply at all times with the American Veterinary Medical Association's and the Marin Humane Society's stated guidelines for humane euthanasia. The contractor has strictly adhered to those recommendations.
During five years of environmental analysis, the NPS considered the option of retaining smaller populations of axis and fallow within the Seashore. This option was not chosen for several reasons:
  1. Populations of both deer species have the capacity to grow very rapidly, as much as doubling their numbers every four to six years. Control would have to be carried out forever. Since contraception has not proven to be effective for controlling large populations of free-ranging wild deer, lethal culling would be necessary. Lethal culling in perpetuity would result in thousands of deer culled. In fact, models developed for the NPS by population biologists suggest that up to 10,000 deer would be killed by 2066 if control, and not total removal, were the goal.
  2. Controlling deer in perpetuity would require immense resources. It is estimated that controlling both populations to 350 individuals of each species, using both culling and contraception, could cost $13 million by 2066. Such funds are not currently available to the Seashore. In addition, controlling non-native deer would require re- allocation of Seashore staff time away from other priorities, such as endangered species protection and other native species management. These priorities would suffer as a consequence.
  3. Controlling non-native deer would reduce impacts to native ecosystems but not eliminate them. Point Reyes National Seashore is mandated by its own enabling legislation to administer its lands "…consistent with, based upon, and supportive of the maximum protection, restoration and preservation of the natural environment within the area." Preservation of non-native deer, and their ongoing damage to the Seashore ecosystems, is not in keeping with the purposes for which the Seashore was established.
Because of the rapid population growth and expansion of non-native deer towards and beyond park boundaries, park managers are concerned that large numbers of breeding females could soon be beyond NPS control. If this happens, nonnative deer expansion over the rest of Marin County will be irreversible and the damage found in the Seashore will occur over larger and larger areas.

Axis deer populations can double every four years, and four-month old fawns have been found to be pregnant. Fallow deer populations can double every six years. At their current densities, non- native deer eat over one ton of forage each day that is consequently not available to native species.

The window of opportunity for controlling the non-native deer is closing. If the NPS does not act now to control fallow and axis deer, they will continue to expand beyond park boundaries onto private and other land. Once outside the park, control will be difficult or impossible.
It took much longer than fifty years for the native species in the California ecosystem to evolve together and form the ecological webs and landscapes you see today at Point Reyes National Seashore. The crucial distinctions between natural evolution of native species and introductions of non-native species is the time scale over which it occurs and lack of human manipulation. A species of plant or animal is generally considered to be “native” if it occupied or migrated to an area over this long period of evolutionary time. The evolutionary timescale is on the order of thousands of years. Fifty years, the length of time during which non-native deer have lived in the area, is a fraction of the time required by most species (particularly long-lived ones) to co-adapt and co-evolve. The distribution and migration of a species is considered to be a natural occurrence if it occurs without the intentional or inadvertent influence of humans. Native species inhabiting the national parks either co-evolved at that location over millennia or migrated there over time.

Axis deer and fallow deer both evolved, over many thousands of years, in India and Asia Minor, respectively. In their native ranges, the vegetation, wildlife and other living species co-evolved with them, to form a stable ecological balance. None of the species present in the natural California coastal ecosystem evolved with axis and fallow deer or appear to be dependent on them in any way. However, the ways in which non-native deer affect native ecosystems are numerous but subtle. Unlike native black-tailed deer, they congregate in massive herds and cause compaction and erosion of soils, denudation of vegetation and damage to woodland and riparian habitats. The species which depend on these areas, including species of concern and migratory birds, are in turn adversely impacted by a loss of habitat. Non-native deer compete with native deer for food and cause decreased survivability of black-tailed deer in the fall and during droughts.

Because of these impacts to native species and the physical structure of the California coastal ecosystem within the Seashore, the National Park Service is mandated to control the non-native deer.

Last updated: September 2, 2019

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