When
 I first heard of the CWD study at Shenandoah National Park back in 
2012, the first thought that entered my mind was that this was just the 
preliminary step toward a drastic herd reduction in the park. As it 
turns out it seems my worst fears are going to be more than realized, 
but for some time park officials seemed to  divert attention away from 
what they really intended to do and to downplay the severity of it. 
In a News Release dated December 5, 2013 
 SNP officials announced that their  staff had completed a planning 
process for a Chronic Wasting Disease (CWD) Detection and Assessment 
Plan.  This followed the park  receiving a Finding of No Significant 
Impact (FONSI) decision. The purpose of the CWD plan at that point was 
to establish a framework in which SNP officials could determine whether 
CWD was present in the deer population within the park and if was found 
to determine the number of infected animals and their location in the 
park.  This would all come together in a   management plan to deal with 
CWD in the park and to co-operate with the Virginia Department of Game 
and Inland Fisheries in detecting the disease, etc.
The news release went on to list four options for the detection and/or assessment of CWD within the park.,
 1. Opportunistic sampling (mostly testing road-killed deer)
 2. Targeted surveillance(looking for and sampling sick/emaciated deer)
 3. Enhanced live-testing (live-sampling healthy appearing)
  4. Lethal removal
At
 this point the lethal removal option appeared to be downplayed as the 
third paragraph of the news letter states, "Sampling will occur in areas
 of the park within 30 miles of a known CWD case. If needed to achieve a
 statistically valid sample size for the detection or assessment of CWD,
 the park may lethally sample up to 150 deer over a three year period 
for detection or approximately 70 over a two year period to determine 
prevalence and distribution. The park will only lethally remove deer for
 sample after exhausting all other non-lethal sampling methods (e.g., 
enhanced opportunistic (mostly road-kill), enhanced live-testing, and 
hunter-harvest/road-kill testing by the VDGIF within the surveillance 
area).The park will primarily sample and remove deer near the closest 
developed areas (e.g. Dickey Ridge, Mathews Arm, Skyland,and Big 
Meadows). Deer will be sampled from developed areas because these areas 
have higher deer densities and are, therefore, at greater risk of CWD 
introduction and spread .Lethal removal sampling would occur during 
periods of low visitation."
Pay special attention to this sentence from the paragraph above, 
"The park will only lethally remove deer for sample after exhausting all other non-lethal sampling methods".  If
 someone read this in a positive frame of mind, it tended to relieve 
their concerns as it gave the impression that lethal removal was 
extremely unlikely to happen or be minor in nature if it did
,  but if we jump forward to late 2014 and read the 
SNP  CHRONIC WASTING DISEASE DETECTION AND ASSESSMENT PLAN AMENDMENT of October 2014
 it becomes clear that they did employ lethal sampling methods on park 
deer or at least they certainly seem to say that they did.
If one goes to page 21 and looks  under the heading, 
"Impacts of plan with addition of proposed response actions"
 they state, "As previously analyzed (NPS 2012a), the current detection 
and assessment actions have some adverse impacts on visitor use and 
experience when visitors are unable to access certain areas of the park 
because area closures are required for safety reasons during lethal 
removal for sampling". They go on to point out on page 22 that "The 
addition of the proposed response actions may require
additional area closures to conduct density reductions but these
are not expected to noticeably change the level of impact on
visitors beyond what was previously analyzed for detection and
assessment actions, alone." Even if one reads the document quite closely
 there are times that you are not sure if they are writing about 
something that has already happened or if they are stating that 
something that is to happen in the future will result in little 
difference in visitor experience, over something that has already been 
planned for the future, but not yet implemented--it is that vague. .
The
 conclusion on page 23 does a good job of summing it up; however, and 
seems to leave little doubt that that they have already removed deer by 
lethal means when beginning with the second sentence they say "The 
adverse impacts of area closures for
density reductions would not be noticeably different than what
visitors currently experience when areas are closed for lethal
removals for detection and assessment.  Closures for density
reductions may be somewhat longer or at different times of the year,
but the overall adverse impacts would not change from existing,
either individually or cumulatively".
Concerning negative impacts, the conclusion states, "The main difference as a result of
adding response actions is decreased opportunities for visitors to
regularly view and photograph deer in favored locations such as Big
Meadows.  Deer would still be present but in smaller numbers, on a
less regular basis, and may be less tolerant of human presence.  This
would probably reduce the enjoyment of visitors who come to the park
specifically to see deer in Big Meadows and other favorite viewing
areas.  It goes on to justify the herd reductions by pointing out that, "This would not reduce the overall
visitor experience of the park because deer densities in these areas
would be more similar to natural deer densities that occur throughout
the park, which is in keeping with the natural conditions and
experience that the park was established to conserve and promote."
The conclusion sections ends with, " Public outreach and information may  promote greater understanding of
the need for the response actions, alleviating some of the adverse
impacts".
 Thoughts  From Blog Readers
 Wildlife biologist, Kirk, commented on my last post, . " If your interest is in the conservation of the whitetail herd, let's 
agree that the current density of WT's on NPS property from Shenandoah 
to Gettysburg is somewhere between 20 and 50 TIMES the threshold for 
"high likelihood" of transfer of CWD as it's practiced in much tougher, 
sparse terrain out west.  Not 20%.  2000%!  And that number is likely 
pretty low.
I'm not arguing this as a hunter (Lord knows that 
hunting on NPS ground is a debacle at best), but as an actual wildlife 
biologist.  Photography is important.  Visitors (and fee payers) are 
important.  But there's absolutely nothing in anyone's action plan to 
reasonably react to a 50% or 80% herd die off."
(I 
assume from this that he is meaning that  a 50% or 80% mortality rate 
from CWD is possible  rather than the lower rates usually reported  in 
states like Colorado are because of the much higher deer density in 
SNP.)
Kirk goes on to say, "There's no "non 
harsh" way through this, is what I'm proposing.  Thanks for bringing up 
the issue, I hadn't heard about this, and I'm well versed in NPS' 
typical aversion to lethal management of anything, even exotic 30 foot 
long pythons."
Kirk  also made a follow-up comment-" Also keep in mind that all of these actions occur in context of 
multiple, often competing, management plans for the NPS units. NPS has 
been burned badly in court numerous times for not aggressively acting to
 take precautions to preserve designated habitats and species from 
"forsseable" threats.  Whitetails are at a high density on NPS lands, we
 all agree on that, and guess what, they don't eat the invasive plants."
A
 Virginia wildlife photographer, Larry W. Brown, who is very familiar 
with SNP said, "To state that this is a bad situation for the SNP 
whitetails would be a 
major understatement. The ignorance of the SNP wildlife management 
officials to continue on with these herd reduction plans makes no sense 
whatsoever. There have been 7 known cases of CWD in that county since 
2009, so if CWD was as bad as they make it out to be, wouldn't the deer 
populations in that area have already suffered? And have already spread 
into SNP? Since 2002, over 7,600 deer in Virginia have been tested for 
CWD. The Va DGIF has diagnosed ONLY 7 positive cases of CWD in Virginia.
 The statistics speak for themselves. 
Another Virginia
 wildlife photographer, Jim Fields, who I first met on A Sunday summer  
morning in Big Meadows back in the film photography day,s  chimed in 
with a very relevant comment, "  SNP is using CWD as a scare tactic to 
convince the unknowing public 
that an 80% cull is needed in Big meadows.  If CWD was a valid concern 
the parks efforts would focused at the North Entrance of the Park nearer
 to the CWD positive specimens. As Larry mentioned Virginia does not 
have mass numbers of deer killing over from CWD. There has only been 7 
CWD positive deer found to date and none of these were in SNP. 
As
 you know in the Amended plan there is no mention of herd management 
with consideration given to keeping genetically strong specimens or 
proper buck to doe ratios to produce quality bucks, does, and fawns for 
 future generations. This is purely a kill plan to eliminate mass deer 
numbers specifically in Big Meadows. 
Additionally If you visit 
SNP you will find no information regarding this subject displayed for 
the public at any of the park facilities. I purposely went in the Byrd 
visitor center yesterday I was handed a copy of the press release from 
behind the counter only after I inquired about the deer reduction in BM.
  There was no copies of the amended plan available at the center."
Another wildlife enthusiast,  Kaleen, said, " The Shenandoah National Park situation is heartbreaking.  I have been 
going to the park for over 40 years and have loved and photographed the 
deer and other animals all that time. The park's plan is insane and 
illogical.  There is not enough evidence to support such drastic action,
 and the only way to completely prevent this disease in the future would
 be to eliminate all the deer, which the current park plan would almost 
do.  The park has ruined wildlife photography, to say nothing of the 
suffering, evident in photos, of the collared deer.  The poor deer do 
not stand a chance, and this planned nighttime shooting will lead to 
poor shots and injured and suffering deer.  The whole plan is senseless 
and will do nothing to prevent the disease from ever reaching the park, 
which is not likely anyway.  The park officials seem to have lost their 
minds.  They should take a lesson from Pennsylvania's game management."
My Thoughts 
When
 we sift to the bottom of all of this it boils down to the fact that 
they are willing to sacrifice 80% of the deer herd at the popular 
whitetail areas such as Big Meadows because, according to Larry Brown , 7
 deer have tested positive for CWD in the State of Virginia and this is 
confirmed by 
The Virginia Department of Game and Inland Fisheries Website.
Remember
 they intend to Shoot 80% of the Big Meadows herd because of  SEVEN (7) 
positive deer in the entire state of Virginia, although it does appear 
that they need to find a positive deer within the 5 mile trigger 
distance from the park or within the park itself to begin the 80% 
reduction. According to a chart on page 8 this means the removal of 
130-150 deer from the Big Meadows area to match the populations density 
of surrounding areas, yet  already  reports are surfacing of experienced
 outdoors people seeing only a few deer in the Big Meadows Area. Does 
this mean that a substantial number of deer have already been removed 
from the Big Meadows area to provide the samples needed for lethal CWD 
testing if enough specimens were not available from non-lethal methods?
Of
 course the fear is that CWD will spread and become established 
resulting in a permanent herd reduction if nothing is done, but even the
 most optimistic official in my experience will not contend that CWD 
response plans as implemented by any conservation or federal agency has 
any chance of stopping the disease--only in slowing the spread of it.  
Remember-To
 slow the spread of the disease down they plan to shoot up to 80% or the
 herd to prevent a loss that in a worst case scenario MAY reach 80% of 
the herd, but would more likely top around 30% and this is assuming that
 the disease becomes widely established in the park, which is by no 
means a given.
It is always easy to criticize, but 
much harder to be responsible for a plan of action, so it is fair to ask
 what would you do if you were in charge of the situation?
 If
 I were responsible for the management of the SNP whitetail herd I would
 manage the herd much as it was before the inception of the CWD study of
 2012.  Only visibly sick or injured animals would be removed from the 
herd and there would be no preemptive shooting.  Expenditure of funds 
and efforts would be geared toward finding a cure for the disease if 
possible. It may be that this is something like the gypsy moth was with 
the oak forests and it will run its' course regardless of efforts 
applied to stopping it.
As it stands,  The SNP plan is 
currently being implemented and future amendments will likely meet with 
approval.  At this writing it appears that the outstanding whitetail 
viewing and photography  at SNP are over for my lifetime and perhaps for
 all time although it is to be hoped that at some point in the future 
responsible people will shake their head at the way war was declared on 
the whitetail deer in the name of saving them from CWD.
A special  thanks to those who submitted comments  on the November 
12th post "Herd Reduction Looms For Shenandoah National Park Whitetails, which are featured in today's post.
Originally 
Published at Pennsylvania Wildlife Photographer by Willard Hill.