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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
An Investigation in Fulfillment of Requests by Former and Current State Officials:
• Office of the Governor •
• House Game and Fisheries Committee •
• Members of the Senate and House of Representatives •
• Board of Game Commissioners •
By
John Eveland
Forester, Wildlife Biologist, and Ecologist
April 17, 2018
Prepared for
• The Office of the Governor •
Governor Tom Wolf
• Pennsylvania House of Representatives •
Mike Turzai, Speaker
and
Members of the House
• Senate of Pennsylvania •
Joseph Scarnati, President Pro Tempore
and
Members of the Senate
• Office of the Auditor General •
Eugene DePasquale, Auditor General
• Sportsmen and Citizens of the Commonwealth •
In 1998, the Pennsylvania Game Commission arbitrarily abandoned its traditional legislated mission and
adopted a new DCNR/Audubon philosophy that resulted in a dramatic and permanent reduction of the
statewide deer herd, a devastating loss of hunters, and a multi-billion-dollar economic impact to rural
communities, the outdoor industry, and the Commonwealth. In addition to the deer-reduction program
being the greatest conservation mistake in the history of the Game Commission, it was and remains a
gross and deliberate violation of Title 34, Section 322 (c) (13).
PGC 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.
For decades, PGC’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. The PGC 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. PGC 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.
Overview
1. A few state employees have changed the mission of the PGC to fit their personal agenda.
2. 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.
3. This change in 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).
4. As a result, 2,500,000 deer were killed over a 5-year period from 2000-04 from a previously stable and
healthy population of 1,500,000 deer, reducing the statewide population by 60% and collapsing deer
densities to as low as only 1-2 deer per square mile in some regions. PGC has continued excessive pressure
on the herd to maintain low densities of deer from 2005 to the present.
5. This action 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).
6. Virtually no benefits were achieved by the action:
• not for science.
• not for tree-seedling regeneration and the forest ecosystem.
• not for commercial forestry.
• not for biodiversity (nongame birds and mammals, wildflowers, and native shrubs).
• not for deer health.
• not for society and the commonwealth's economy.
• and not for sportsmen and recreational hunting.
7. The need to increase forest tree-seedling regeneration was a principal reason PGC 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.
8. PGC has failed to create adequate habitat for wildlife, placing deer, grouse, and about 150 species of wildlife
at risk. PGC has declined to create adequate habitat because cutting trees would have generated tens-of-
millions-of-dollars for PGC and eliminated the agency’s justification for a license-fee increase – a deception
and violation of The Pennsylvania Constitution, Article I, Section 27.
9. The negative impacts to the natural ecosystem, society, and economy are severe, unjustified, and increasing
yearly. The deer herd has been reduced to nearly unhuntable numbers in some areas. 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. 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. Deer reduction has become
a crisis that likely represents the greatest conservation mistake in the over-100-year history of the PGC.
10. This crisis must now be resolved. No permanent solution will result from conciliatory remedial actions by
the Commission. Considering that the agency has violated its public trust, it has become the responsibility
of the Joint Legislature to resolve the crisis. A professionally designed bill has been prepared to resolve the
crisis and that is in the best interests of all factions. HB 1483 should be passed immediately.
Table of Contents
Executive Summary
Section 1. Introduction / Official investigation requested by the Governor and General Assembly.
Section 2. If it ain’t broke, don’t fix it.
Section 3. The relationship between DCNR’s Green Certification Program and PGC Deer Reduction.
Section 4. Regarding their first goal – generating increased revenue for DCNR.
Section 5. Regarding their second goal – the anti-deer, environmental agenda.
Section 6. Audubon facilitated deer reduction and the switch to a new ecosystem management policy.
Section 7. DCNR’s unspoken reason to seek deer reduction – old growth forests
Section 8. DCNR’s CNRAC advisory council has been influencing PGC’s deer management program.
Section 9. By the numbers: How PGC dismantled the deer herd (2000 to the present).
Section 10. PGC was discovered to be falsifying data using infrared (FLIR) technology.
Section 11. PGC Relied Exclusively on Seedling Regeneration to Justifying Deer Reduction.
Section 12. PGC replaced Alt with three Chesapeake Farms students to continue deer reduction.
Section 13. PGC’s deer-management program is not based on sound science.
Section 14. A Perfect Storm: PGC and DCNR designed a doomsday scenario to virtually exterminate deer.
Section 15. Pennsylvania is ranked #1 as the worst hunting state in the nation.
Section 16. PGC failures are costing the state $1.2 billion in lost economic activity and $92 million in lost tax revenue.
Section 17. PGC’s Impact to Ruffed Grouse -- the Commonwealth’s State Bird.
Section 18. PGC’s Impact to Wildlife Resources.
Section 19. A Socio-Economic Disaster.
Section 20. Sportsmen Hate PGC’s Deer-Management Program.
Section 21. PGC’s deliberate violation of State Law.
Section 22. PGC is playing a political game and deceiving legislators.
Section 23. Should PGC be rewarded for what it has done?
Section 24. Summary and Discussion.
Section 25. Conclusion and Recommendations.
Appendix A-H. See separate appendices for contents of each appendix.
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
Disregarding laws and rules: Leaders picking and choosing what laws to follow has promoted the “do
whatever” mindset that is so prevalent in America. When government officials and employees blatantly
ignore laws simply because they don’t agree with them, they should be held accountable. When they are not,
such behavior becomes mainstream.
Executive Summary. 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. This MSY method had created a Pennsylvania
reputation as one of the top deer-hunting states in the nation, satisfied the hunting interests of over a million sportsmen,
maintained a vibrant multi-billion-dollar outdoor industry, and provided ample deer, other game, and nongame animals to
keep family cabins and hunting camps filled. It served the recreational interests of the many millions of wildlife
enthusiasts and outdoor-loving citizens of the Commonwealth. 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. This traditional and successful game management philosophy was abruptly ended by PGC in 1998
at the request of DCNR and at the personal discretion of only three men. The action soon escalated into the greatest
conservation mistake in the history of the Game Commission and represents a violation of Title 34 (The Game and
Wildlife Code).
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. 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. Therefore, herd
reduction was initiated for two reasons: to increase DCNR timber-sale revenue, and to advance an anti-deer,
environmental agenda.
Toward achieving these goals, under pressure from foresters and extreme environmentalists, in 1998 PGC discarded its
traditional, time-tested, scientific, MSY method of game management and adopted a new DCNR/Pennsylvania Audubon
style called “ecosystem management”. Instead of serving the interests of sportsmen and hunting as is directed in Title 34,
under the new system PGC had arbitrarily chosen to prioritize tree seedling regeneration, wildflowers, and nongame
wildlife such as songbirds over deer – the Commonwealth’s State Mammal and flagship of hunting and the outdoor
industry. According to the DCNR/Audubon/PGC method, in order to achieve their new goal the deer herd needed to be
permanently reduced in size to the lowest possible degree that would serve forestry and environmentalist interests (zero
deer) while sustaining enough deer to maintain hunter interest toward keeping the herd permanently reduced. This new
arbitrarily chosen mission was implemented in 2000 by PGC in compliance with DCNR’s deer-reduction request, and it
remains in direct violation of PGC’s chartered mission as legislatively directed in Title 34: The Game and Wildlife Code.
In accordance to DCNR’s Green Certification request, from 2000-04 PGC killed 2,500,000 deer, an average of 100,000
additional pregnant does and fawns over the average annual harvest of 378,000 deer that had occurred in the 1980s and
‘90s. Over this five-year period, the statewide herd was reduced by 60% from an estimated 1,500,000 deer to only
600,000. PGC’s board of commissioners’ president stated that the agency’s goal was to reduce the herd to only 5-6 deer
per square mile (dpsm), but that the Commission had mistakenly overshot this target, leaving only 1-2 dpsm throughout
large regions. In 2005, PGC attempted to halt the overkill and dramatic reduction period, and to stabilize the herd at this
new, low deer density that represented a virtually unhuntable condition for sportsmen in many regions. Nevertheless, the
next year PGC announced a near-record deer harvest and has continued to claim near-record harvests equivalent to the
heydays of deer hunting in the 1980s and ‘90s even though the herd had been reduced by 60% in some regions and over
90% in other regions. According to deer biology and herd population dynamics, if PGC’s estimates had been correct deer
would have been exterminated from Pennsylvania by 2008, and if their current harvest claims were correct, the
Commission would have had to have stocked 3,461,251 deer from other states between 2005-17 and shot every one of
them. Explaining PGC’s false annual harvest claims in another way, in order for PGC’s claims to be accurate there would
have needed to be 2,338,645 deer in the state from 2005 to the present. This would represent a density of 84 deer per
square mile (dpsm) on every parcel of forested land down to an acre in size, or 50 dpsm covering all the land area in the
state -- including the city streets of Harrisburg, Pittsburgh, and Philadelphia, as well as covering the highways, backyards,
playgrounds, and ballfields of the Commonwealth. Considering that PGC recently claimed that they wish to increase the
herd to 10 deer per square mile in northern-tier counties and eventually maybe to 15-20 dpsm, this would mean that the
remainder of the state would need to be harboring a density of about 166 deer per square mile -- of course a biological
impossibility.
PGC hired three NC State University students as the agency’s deer-management team. All three had been trained on a 5-
square-mile agricultural demonstration farm in Maryland called Chesapeake Farms -- not as conventional wildlife
biologists, but, instead, on methods to reduce deer in order to decrease impacts to farm crops. PGC hired them to expand
their training to a statewide level by permanently reducing Pennsylvania’s deer herd. 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”. 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__”. These circumstances indicate the need for increased
accountability by the Legislature.
This Green-Certification/deer-reduction scheme soon proved to be a socioeconomic disaster. 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 an attempt to justify their action, PGC and DCNR conducted extensive studies after-the-fact toward 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. However, multiple studies dispelled this belief. Instead, 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. PGC
has not only made an egregious conservation error by decimating the deer herd for a mistaken belief and for no good
reason, but the Commission has been exacerbating the damage by refusing to adequately create desperately needed
wildlife habitat through cutting the old forests to provide early stage, young forests of much higher productivity for many
species of wildlife. For example, during the past three years PGC has improved habitat on only about one-third of one
percent of its state game lands holdings per year – cutting only 1% of timber for habitat enhancement every three years.
The Ruffed Grouse Society is urging Pennsylvania to create 10% early stage habitat per year to benefit grouse
populations, alone.
As a result, not only have deer and grouse suffered because of PGC’s mismanagement of wildlife and forest resources, but
also about 150 species of wildlife that are now in decline or at imminent risk – a circumstance that places PGC in direct
violation of the Pennsylvania Constitution’s directive to wisely manage the state’s natural resources for all the people.
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.”
The impacts of PGC’s mismanagement of forests and wildlife have resulted in the effective loss of an estimated 270,000
hunters, an annual impact of $1.16 billion to the state economy and a cumulative loss of $10 billion from 2000 to 2017,
the loss of an estimated 13,000 jobs, the loss of a calculated $92.5 million per year in government tax revenues, uncounted
bankruptcies and family business closures, empty family cabins and closed hunting camps, an extreme lack of wildlife for
the recreational enjoyment of millions of the state’s citizens, and a risk to the future of sport hunting in Pennsylvania.
Therefore, the PGC stands in direct and deliberate violation of both Title 34 (The Game and Wildlife Code) and The
Pennsylvania Constitution. The agency is unwilling and unable to resolve the deer management and wildlife habitat
crises. Resolution resides in the hands of the Pennsylvania Legislature to begin a new era of oversight that will hold the
agency accountable and correct this conservation dilemma. House Bill 1483 (HB 1483) was designed specifically for this
purpose.
Section 1. Introduction / Official investigation requested by the Governor and General Assembly. For
over a century, the Pennsylvania Game Commission (PGC) had competently managed the wildlife resources of
the Commonwealth: (1) conserving game animals with respect for the ability of the forest to sustain harvests in
the interest of sportsmen for recreational hunting, and (2) preserving nongame birds and mammals for the
benefit of all citizens. PGC's wildlife and forest management balance of art and science had maintained a
diverse ecosystem rich with native flora and fauna, and a hunting reputation of national acclaim. For decades,
Pennsylvania was recognized as one of the top deer-hunting states in the nation.
However, the turn of the new millennium witnessed a change in PGC's wildlife management philosophy that
shifted the focus away from the pursuits of traditional game management and sport hunting, and toward
nongame management and forestry interests. As a result, over a five-year period from 2000-04 PGC
implemented a drastic statewide deer herd reduction program and has kept the herd at an exceedingly low level
from 2005 to the present. Although the agency claimed that this unprecedented action was a scientific
necessity, many sportsmen, legislators, and members of the agency's own board of commissioners questioned
the wisdom of the new policy.
John Eveland is an independent, professional wildlife biologist, forester, and ecologist who has been asked by
state elected officials to assess PGC’s deer and wildlife management programs. Until independent scientific
investigations were conducted that culminated in reports by Eveland, sportsmen and decision-makers within the
State Senate and House of Representatives, the Office of the Governor, and PGC's Board of Commissioners
have had little recourse but to trust in the integrity of the agency to honorably uphold its legislated mission. To
date, little has been done either internally by the agency or by legislative action to resolve what has been
deemed as the greatest conservation mistake in the over-one-hundred-year-history of the Pennsylvania Game
Commission.
In 2000-01, John Eveland was asked by the Senate Minority Leader to assess PGC's deer-reduction program.
In 2007, he was requested by the Office of the Governor and, again, from 2008-09 by the Majority Leader of
the House Game and Fisheries Committee and other bipartisan committee members to determine if the Game
Commission's deer, forest, and wildlife management policies were scientifically valid and socioeconomically
responsible. In 2010, members of PGC's Board of Commissioners asked Eveland to prepare a new deer
management plan for them in the event that they could muster a majority of votes to halt the deer-reduction
program. Their vote was split, and, therefore, not initiated. Because of the egregious magnitude of the impacts
to the deer herd, sport hunting, wildlife resources, society, and the Commonwealth’s economy, the only
recourse toward resolving this conservation crisis was through legislative action. HB 1483 was designed for
this purpose and is based on the management plan that had been previously requested by PGC’s Board of
Commissioners.
From Eveland's investigations, there are two over-riding conclusions: (1) that 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. As such, the Pennsylvania Game Commission has been in direct and deliberate
violation of State Law -- PGC's legislated mission as directed in Title 34 (The Game and Wildlife Code) as well
as The Pennsylvania Constitution. Therefore, there is no reason that PGC's deer-reduction program should have
been initiated in 2000 nor continued to the present, and there are overwhelming reasons for the program to be
immediately ended.
This Part I of two reports describes the reason that PGC intentionally dismantled the deer herd and violated both
its Title 34 mission and The Pennsylvania Constitution. Myriad original documents from 1996 green
certification contracts and related newspaper articles and government memos to ecosystem-management,
Chesapeake Farms, DCNR and PGC strategic plans, and other related documents as discussed in the following
20 sections are available upon request. Some pertinent figures are provided in an appendix at the end of this
report. A separate Part II report describes Pennsylvania House Bill 1483 (HB 1483) -- the solution to PGC’s
violations of the rule of law, mismanagement of deer and wildlife resources, failure to create adequate wildlife
habitat, and high and unacceptable socioeconomic impacts to rural communities and the Commonwealth.
Section 2. If it ain’t broke, don’t fix it. For decades prior to 1998, the Pennsylvania Game Commission had
embraced a traditional game management philosophy that produced the maximum sustainable yield of deer and
other game animals for sport hunting, over a million hunters, a healthy forest ecosystem with a diverse wildlife
community, and a vibrant multi-billion-dollar outdoor industry. Dozens of Pennsylvania counties, thousands of
family businesses, and tens-of-thousands of jobs relied on a sustainable deer herd and abundant wildlife.
Pennsylvania was recognized as one of the top two deer-hunting states in the nation and deserved that national
acclaim. However, from 1998-2000 PGC eliminated this traditional “MSY” game management philosophy and
designed a new approach to deer and wildlife management that was sensitive to the requests of the Department
of Conservation and Natural Resources and DCNR’s two forestry and environmentalist special interests.
Section 3. The relationship between DCNR’s Green Certification Program and PGC deer reduction. In
1998, DCNR 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. At the time, it was
claimed to be a pilot program for the nation. According to this mutually-beneficial scheme, the seller of the
award (FSC) would generate great sums of money toward advancing the agendas of international environmental
organizations, while the buyer (in this case, DCNR) would increase its timber-sale revenue. Therefore, the
planned, annual DCNR Green Certification Award was intended to give environmentally-minded retail and
wholesale customers the impression that lumber from DCNR’s state forests was superior to lumber and wood
products from other landowners, and, therefore, domestic and international sales of DCNR lumber would
increase. In reality, however, 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.”
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. (See Appendix A.)
Section 4. Regarding their first goal – generating increased revenue for DCNR. This scheme soon proved
to be a socioeconomic disaster for the state. 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.
Section 5. Regarding their second goal – the anti-deer, environmental agenda. In 1998, PGC complied
with the request of DCNR’s forestry chief and Bryon Shissler (the regional representative of the international
environmental organization (FSC)) by switching from its decades-long, traditional wildlife management policy
that favored the interests of sportsmen and the citizens of the Commonwealth (as was directed by state law in
Title 34 and the Pennsylvania Constitution, respectively), and adopted a new style of management that favored
two special interests – foresters and a small group of environmental organizations. While a study that was
funded by the Pinchot Institute discovered that every other state in the nation used some form of PGC’s former,
traditional, MSY method which had made PGC one of the top two deer-hunting states in America, this new-age
style – called ecosystem management – was based on agenda-driven politics instead of science.
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.
The switch from traditional game management to the new ecosystem management approach was designed and
implemented at the discretion of the above-listed three men who chose to ignore PGC’s legislated mission in
order to achieve their personal agenda. While the Green-Certification program’s principal intent was to
increase timber-sale revenue for DCNR and any other landowner who would buy into the program, the deer-
reduction/ecosystem-management provision was inserted into the contract in order to increase seedling red oak
regeneration as a future cash crop for DCNR and PGC and to improve nongame wildlife, songbirds,
wildflowers, and native shrubs. Both PGC and DCNR believed that these goals could all be achieved by
permanently dismantling the state’s deer herd -- Pennsylvania’s State Mammal and flagship of hunting and the
outdoor industry – in that, they believed, deer over-browsing was preventing the regeneration of the forest
understory. (This, however, was to be later learned to not be the case.)
Toward accomplishing their personal agenda, PGC biologist Gary Alt was switched from the bear-management
program and assigned the task of designing the planned deer-reduction action, convincing sportsmen that the
reduction program was in their best interest and would be limited and temporary, and convincing legislators that
the action was based on sound science and necessary. Therefore, from 2000-04 PGC orchestrated the killing of
2,500,000 deer, an extra 100,000 pregnant does and fawns above the average annual harvest of 378,000 deer.
By 2005, the statewide herd had been reduced by 60% (and over 90% in some regions) to only about 600,000
deer, and if it had continued at that rate, deer would have been eliminated from the state by the fall of 2007.
In 2005, PGC attempted to back-off the assault and to stabilize the herd in perpetuity at these reduced numbers.
This experiment was soon recognized as a dismal failure and has been acknowledged as the greatest
conservation mistake in the over-one-hundred-year history of the agency. According to Legislative Budget and
Finance Committee metrics, it is resulting in $1.16 billion per year in lost economic activity, especially to rural
communities, with an estimated loss of 13,000 jobs, a cumulative economic loss of about $10 billion, and an
additional loss of $92 million in annual tax revenue.
While PGC has likely been in violation of state laws including ethics violations, conflict of interest,
inappropriate use of funding, violation of the public trust, and abuse of power for the past several years, since
2000 the Commission has been in deliberate violation of its Title 34 mission and The Pennsylvania
Constitution.
Section 6. Audubon facilitated deer reduction and the switch to a new ecosystem management policy.
(a) Regarding Audubon and ecosystem management/deer reduction, in 2001, Cindy Dunn, Executive
Director of Audubon Pennsylvania, initiated a multiple year process to design a 364-page document entitled
“Managing White-tailed Deer in Forest Habitat from an Ecosystem Perspective” that would serve as a template
for PGC’s deer-reduction program and the change-over by PGC and DCNR from traditional deer management
to the new form of game and wildlife management called “ecosystem management”. Quoting from the first
sentence of the preface: “In April 2001, the Pennsylvania office of the National Audubon Society and the
Pennsylvania Habitat Alliance asked a group of professionals to look at deer management from an ecosystem
perspective. …the group was asked to describe how deer management might differ from current practices if
deer were managed within an ecosystem framework that aims to conserve native biodiversity.” (See Appendix
B.)
Among those included in the group were Cindy Dunn, Bryon Shissler, and DCNR’s Merlin Benner. When the
document was completed a few years later, among the acknowledgments Audubon thanked PGC’s Robert
Boyd, Calvin DuBrock, Chris Rosenberry, and Vernon Ross for their participation.
Under the heading “Major Findings Regarding Policy and Administration”, this ecosystem-management,
master-plan document concluded:
• “The goal is to bring back the understory vegetation.” This, they believed, would be accomplished via
permanent and dramatic deer reduction.
• “With the exception of a vocal minority of hunters, there is a broad consensus that deer densities in
Pennsylvania are too high from an ecosystem perspective.”
• “Enhanced DMAP regulations that allow more liberal harvest of antlerless deer on state forest lands and are
granted to the D.C.N.R. Bureau of Forestry.”
• A “legislative fiat, whereby administration and control of deer hunting regulations on District Forests are
transferred from P.G.C. to D.C.N.R..”
• Merger of P.G.C. with D.C.N.R. in a combined natural resource agency resulting in oversight of hunting
regulations by a more balanced representation of natural resource interests.”
In summary, Audubon’s conclusion was to remove deer management from PGC (and sportsmen) and to give it
to DCNR – which favored the interests of foresters and environmentalists. PGC personnel participated in
developing the Audubon report, and adopted the “ecosystem management” approach to deer management.
(b) Regarding DCNR and ecosystem management/deer reduction, in February 2009, DCNR’s Chief
Forester, Dan Devlin (one of the three original architects of the deer-reduction/ecosystem-management
program), completed DCNR’s 49-page version of the Audubon “ecosystem management” approach to deer
management called “Monitoring Deer Effects on Forest Ecosystems in Pennsylvania State Forests”. Its authors
included Bryon Shissler and PGC’s Ben Jones and Chris Rosenberry.
(c) Regarding Audubon and the WMI/deer-reduction scenario, 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). In so doing, the responsibility of such a monumental
decision to decimate the deer herd had been shifted from the shoulders of the PGC to the broad spectrum of
interests represented by the DMWG.
It should be noted that Scot Williamson was an acknowledged supporter of deer reduction in Pennsylvania. He
had been one of the principal speakers at the 1999 Harrisburg reduce-the-deer conference which had been
sponsored by Pennsylvania Audubon and the Sierra Club. He was quoted by Ben Moyer in a 1999 Pittsburgh
Post-Gazette Sunday newspaper article as praising those who made such an important first step (in new deer
management) on that day. Therefore, his selection as chairman of the DMWG by PGC was no coincidence, and
he was not likely appointed to be an unbiased participant.
Although it was cited that members of the DMWG were chosen to represent a diversity of special interests
(including hunters, wood products industries, and animal welfare groups), in addition to Scot Williamson, the
DMWG included not only Bryon Shissler, but others such as Cindy Dunn (Audubon), Susan Stout (U.S. Forest
Service), and Ben Moyer (outdoor writer) who were adamant supporters of deer reduction, and who have
remained long-term leaders of the deer-reduction program. In January 2000, Chairman Scot Williamson
presented the "Findings and Recommendations of the Deer Management Working Group” to the “Executive
Director and Board of Commissioners, Pennsylvania Game Commission."
Virtually every facet of today's deer management plan was recommended by Scot Williamson, as presented in
his findings to the Board of Commissioners. He recommended the elimination of the county-based management
system in favor of Wildlife Management Units (WMUs), aggressive doe harvesting using increased antlerless
allocations, aggressive hot spot harvesting (DMAP), the concurrent buck/doe season, and other doe harvest
methods. Following the January 2000 presentation by the DMWG (Williamson) to the PGC's Board of
Commissioners, Scot Williamson's recommendations were implemented by the PGC as their new deer
management program. Therefore, Scot Williamson – whether alone or in concert with Bryon Shissler, Calvin
DuBrock, and Gary Alt – had been the designer and author of what would soon become the PGC's new deer-
reduction program.
The services of Scot Williamson would again be used about a decade later in an attempt to validate the PGC's
deer-reduction program. In 2008, Williamson was selected by former Rep. David Levdansky in a pre-designed
process to serve as the auditor of the PGC's deer-reduction program – to determine the efficacy of the program.
He was granted approximately $95,000 of Pennsylvania state funding. Rep. Levdansky was the hand-selected
legislative agent of Audubon (working with Timothy Schaeffer, Executive Director of Audubon Pennsylvania
and successor to Cindy Dunn).
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". Rep. 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. This, however, was not the case.
Some who have been aware of this circumstance have labeled that 2008/09 audit process as a blatant conflict of
interest and a possible abuse of taxpayer dollars, a legislative ethics violation, abuse of power, or violation of
the public trust. This matter, however, will be left for others to determine. Nevertheless, the above
documentation indicates that the recommendations of Scot Williamson's DMWG in 2000, the resulting PGC
deer management program that has continued for 18 years, and the findings of Scot Williamson's audit in 2009
toward validating the deer program, should be considered as being acts of questionable credibility that were
designed toward advancing an agenda that is not in the best interest of the Pennsylvania Game Commission’s
legislated mission nor in the best interest of sportsmen and the citizens of the Commonwealth.
It should be noted that in 2005 Tim Schaeffer (Audubon’s president) had worked with Bryon Shissler, Gary Alt,
and Ben Moyer in developing a short-lived project called The Ecosystem Management Project to create and
distribute a regular publication called “Resource Report”. The subheading read: “A Publication of The
Ecosystem Management Project • Ben Moyer and Bryon Shissler, Editors”. Their articles had one purpose – to
advance a radical anti-deer philosophy in an attempt to justify PGC’s deer-reduction program and keep it in
place. Further, Tim Schaeffer, Shissler, and Alt were regular public speakers toward maintaining PGC’s deer-
reduction program.
Keep in mind that while PGC had just completed the dramatic 5-year primary deer-reduction period from 2000-
04 – having reduced the overall statewide herd by 60% and up to 90% and more in some regions –
nevertheless, PGC began claiming that annual deer harvest rates were still the same as in the heydays of deer
hunting in the 1980s and ‘90s, and PGC has continued to report near-record harvest rates from 2005 to the
present – a biological impossibility. Without accountability, PGC has been able to make any claims that
advance the agency’s agenda
with impunity.
Section 7. DCNR’s unspoken reason to seek deer reduction – old growth forests. In 2002, DCNR along
with The Nature Conservancy established 550,000 acres of State Forests plus 1-2-mile buffers as 400-500-year-
old old-growth forests. DCNR seeks the permanent near-elimination of deer and human development on these
lands. According to DCNR’s published plan, “The proposed old-growth forest must be resurrected from
fragmented and structurally homogeneous second-growth forests that are subject to anthropogenic
disturbances.” In other words, human encroachment such as hunting, energy development, and cabins are
intended to be minimized or eliminated. Most importantly, their plan requires the dramatic and permanent
reduction of the deer population: “Reducing Pennsylvania’s deer population will require a long-term political
process. This will not be easy. For more than a hundred years, the goal was to increase deer….” (See
Appendix C.)
PGC is complying with DCNR’s request for high annual antlerless allocations plus high DMAP allocations.
According to DCNR, in 2002 26-32% of all DCNR state forest stands were included in the old-growth system.
Only 2% of forests were listed in the 0-10-year age class – the age class most valuable as habitat for deer,
grouse, and many other wildlife species -- and DCNR’s policy has been to fence these early-stage forests from
access by deer. In the publication, DCNR projected that by 2140 the old-growth system will have been
increased from 32% coverage in 2002 to 47-55% of all forest stands. This is an unacceptable policy that will
further degrade deer, grouse, and wildlife populations with catastrophic impacts to sport hunting and rural
economies for centuries.
Section 8. DCNR’s CNRAC advisory council has been influencing PGC’s deer management program. In
order to achieve DCNR’s permanent herd-reduction goal, DCNR continues to influence PGC’s deer
management program by having created an 18-member council of volunteers, of which DCNR has assured
control by having the Secretary of DCNR serve as a member. Each year since the onset of the deer-reduction
program, this Conservation and Natural Resources Advisory Council (CNRAC) has sent a letter-of-request to
PGC’s Board of Game Commissioners and to the Governor. These letters have been intended to influence
PGC’s deer-management program in favor of DCNR interests – to maintain deer-reduction pressure on the herd,
to annually increase the already high numbers of antlerless allocations, and to increase the number of DMAP
permits for DCNR’s state forest lands. PGC has complied.
Section 9. By the numbers: How PGC dismantled the deer herd (2000 to the present). As has been the
case for the past eight years, in March PGC annually announces the agency’s estimated deer harvest, and each
year John Eveland holds them accountable by conducting a scientific analysis of their excessively high, false
claim -- demonstrating that PGC's annual claims are greatly exaggerated and based on either incompetence or
deception. If PGC were capable of scientifically assessing their numbers and less concerned with political
agenda, Pennsylvania would not likely be faced with the ongoing $10 billion deer-management crisis.
For the 2017-18 hunting season, PGC claimed that the harvest was up 10% over last year's (2016) harvest,
which they claimed was, itself, up 6% over the previous year's kill. Based on deer biology and population
dynamics of the herd, in order for PGC to have killed 367,159 deer during the past 2017-18 season, there would
have needed to be 2,338,645 deer in the state. This would represent a density of 84 deer per square mile (dpsm)
on every parcel of forested land down to an acre in size, or 50 dpsm covering all the land area in the state --
including the city streets of Harrisburg, Pittsburgh, and Philadelphia, as well as covering the highways,
backyards, playgrounds, and ballfields of the Commonwealth. Considering that PGC recently claimed that they
wish to increase the herd to 10 deer per square mile in northern-tier counties and eventually maybe to 15-20
dpsm, this would mean that the remainder of the state would need to be harboring a density of about 166 deer
per square mile -- of course a biological impossibility. (For details, refer to this year’s full 6-page report
entitled “An Independent, Scientific Assessment of the Pennsylvania Game Commission’s Estimated 2017-18
Deer Harvest” by John Eveland.)
During the intensive five-year deer-reduction period from 2000-04, PGC claimed to have killed 2,500,000 deer
-- targeting an extra 100,000 pregnant does and fawns for harvest in each of the five years. Again using deer
biology and population dynamics, PGC had reduced the long-term stable herd of 1,500,000 deer in 1999 by
60% to only about 604,000 by the spring of 2005. If PGC had continued to kill deer at that rate, by the fall of
2007 deer would have been completely exterminated in Pennsylvania -- zero deer in Penn's Woods. Since
2005, PGC has annually claimed that they are killing 330,000-350,000 deer each year -- this year they claimed
killing 367,159 deer. If this were the case, the deer population would have reach zero by the spring of 2008.
Continuing to the present, in order for PGC's high harvest claims to be accurate they would have needed to
import 3,461,251 deer
from other states and shot every last one of them. Note that for the upcoming 2018-19 hunting season, PGC has
again increased the number of antlerless allocations by 34,000 to 838,000 doe permits. (See Appendix D.)
The above-referenced report demonstrates the high level of incompetence and deception by the PGC. It should
be read by legislators to familiarize them with the unacceptable irregularities that are ongoing by the
PGC. Passage of HB 1483 is the only way to resolve this deer-management and wildlife conservation crisis.
Section 10. PGC was discovered to be falsifying data using infrared (FLIR) technology. For several
months, Jack Iannantuono, Co-Chairman of the Eastern Pennsylvania Firearms Coalition, had been in dialogue
with PGC's Wayne Laroche regarding the density of deer in select areas of eastern Pennsylvania where Jack
resides and hunts. During this time, Laroche had claimed that Commission records indicate that 48 deer per
square mile existed in the area of question – not so coincidentally the precise number of deer that John Eveland
had calculated as being needed to satisfy the Commission's exceedingly high annual harvest estimates of
335,000 to over 350,000 deer per year.
On July 25, 2016, Laroche scheduled a PGC survey of the area between roughly 8-11 pm, which was personally
conducted by Laroche without Jack, using a "Forward-Looking InfraRed" camera (FLIR). To Jack's surprise,
the PGC team reported that they had seen 341 deer over the 14 square mile survey area – representing about 24
deer per square mile. However, Laroche stated that PGC statistical analyses incorporate a 50% factor into the
equation for deer that remain unseen, thus increasing PGC’s results to 682 deer over the 14 mile driving survey
area, and, thus, representing 48 deer per square mile.
This number precisely fits the Commission's predetermined estimated density of deer for the area (48 dpsm)
and, again, is the precise number that Eveland calculated would be needed across the state in order for PGC to
achieve their high annual harvest estimates of 335,00-350,000 deer.
The deception continued, in that Eveland had been forwarded an aerial photo of the overall region and precise
survey area. Upon inspection and verification from Jack and local landowners, it was discovered that the
survey area consisted of a narrow 14-mile strip of woodlots that were interspersed and surrounded by
agricultural fields. The survey area was 75-85% soybean, wheat, and cornfields – primarily soybean – all
favorite foods of deer. Laroche had shown the infrared survey to Commissioners and it was made available on
the Internet in which Laroche and his driving companion showed numerous deer standing in the forest (actually
woodlots between fields) and in forest openings (actually soybean fields). Within days the survey was reported
by the outdoor editor of the Pittsburgh Tribune Review (the western Pennsylvania voice of the Game
Commission) in a tone that was intended to humble hunters who claim that too few deer exist. The Game
Commission had proven that the number of deer that are required to satisfy the agency’s extremely high annual
harvest claims actually exist.
Jack discussed the high numbers of deer being reported by Laroche to a local farmer who laughed and gave the
commission a "raspberry with spit coming from his mouth", according to Jack, at the ludicrous claim that 682
deer (48 dpsm) existed in this 14 square mile area. In actuality, however, considering that 85% of the area is
agriculture and primarily soybean, it would not be surprising if well over 48 deer per square mile existed on the
area – if the local deer herd had not been decimated by the PGC.
And now for the rest of the story! Because this scenario was so nonsensical to Jack, he located a source in
Syracuse, NY where he could rent a FLIR camera. Jack rented the camera for $900/month, learned how to
operate it, and with a friend and their wives duplicated the exact driving survey covering the same stations and
14 square miles as had the PGC on July 25. Jack's survey was held at the same time of day (roughly 8-11pm)
and occurred between 3-4 weeks following PGC's survey. In contrast to 682 deer as had been reported from
PGC’s survey, Jack's survey identified only 54 deer over the 14 square miles – calculated to 3.9 deer per square
mile (considering that Jack did not double his findings). In summary, PGC reported 682 deer over the 14
square-mile survey area representing 48 deer per square mile, while Jack’s identical survey tallied 54 deer
representing 3.9 deer per square mile.
The next evening Jack drove to the north of the area to conduct a similar infrared driving survey on Game
Lands 217. He and his companion saw 9 deer over an 8 square mile area of forested game lands -- calculated at
1.1 deer per square mile.
Section 11. PGC relied exclusively on seedling regeneration to justify deer reduction. On November 15,
2004, four years into their intensive deer-reduction program, PGC and DCNR colluded in what was referred to
as a “secret” meeting that included Carl Roe, Vern Ross, Mike Schmit, Cal DuBrock, Gary Alt, and select
commissioners from PGC; and Michael DiBerardinis, Rick Carlson, Jim Grace, and Merlin Benner from
DCNR. The minutes of this highest-level meeting revealed that the Commission and DCNR were involved in
long-term collaborations to permanently reduce the statewide deer herd; that sportsmen, economic impacts, and
the well-being of rural communities were not considerations; and that PGC believed that they could only justify
such an extreme action if they could demonstrate from a planned DCNR regeneration/browse survey that deer
were destroying the forest. This after-the-fact study was PGC’s first effort to scientifically determine if deer
were, in fact, destroying the forest. Such a study should have been conducted years before as a prerequisite prior
to decimating the statewide deer herd. It was now being conducted to justify the two agencies’ action, and to
assuage sportsmen and legislators who were increasingly questioning the necessity and extensiveness of the
deer-reduction program.
Quoting from the minutes of the meeting:
• PGC: “You need to be patient. If we lose support of sportsmen, we lose funding support from the General
Assembly.”
• DCNR called for more tools to kill deer, including multiple DMAP tags per hunter and extended rifle seasons
with two more weeks of concurrent rifle deer season and an early muzzleloader season open to all weapons, and
wrote a deer plan that included hunting with dogs, night hunting, hunting over bait, and sharpshooters.
• PGC (Gary Alt): “We can’t succeed with baby steps.” However, “Is the system really working? Are we
getting the forest regeneration we want?”
• DCNR (Merlin Benner): “A regeneration study (is needed). DCNR is prepared to take care of the costs.”
• PGC: “Gary (Alt) feels that if we can’t show measurable improvement in habitat, we are in trouble. It will be
the most important study we will ever do.”
Toward this end, 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. 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.
DCNR and PGC had dismally failed in their study’s attempt to demonstrate that deer were the cause of the low
and declining amount of forest seedling regeneration but did not widely disseminate the significance of the
survey. Instead, the report attempted to explain the failure of the study by concluding that the survey was
biased with too little data -- “a work in progress in an adaptive management process.” This study proved to be
Gary Alt’s worst fear in that PGC could not prove that deer harmed forest regeneration, and, therefore, could
not justify what PGC and DCNR had done – collapsed Pennsylvania’s deer herd for no good reason.
Shortly thereafter, 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. To date,
however, PGC has not been held accountable for the severe and continuing conservation, social, and economic
impacts from its deer-reduction fiasco, and continues the relentless assault on the deer herd.
Prior to resigning, Gary Alt stated that PGC needed to maintain the deer-reduction program for at least a
generation. After that time, there wouldn’t be enough old-timers left to remember the good old days, and PGC
and DCNR would have achieved their long-term goal. Unless HB 1483 is now passed in 2018, it is likely that
PGC and DCNR will succeed in their combined goal to permanently decimate the deer herd.
Section 12. PGC replaced Alt with three Chesapeake Farms students to continue deer reduction. In 2011,
John Eveland was notified by PGC’s Board of Game Commissioners that there was a rumor circulating within
the Commission that all three members of PGC’s deer-management team were from the same university. This
was thought to be a strange occurrence, and Eveland was asked if he could ascertain the academic histories of
the agency’s three deer biologists. Eveland complied with the Board’s request. The suspicion of PGC’s Board
was true. Eveland acquired the graduate theses of the three PGC deer biologists who had all been North
Carolina State University students, had all gotten their degrees from the same NC State professor, and had all
conducted their degree research under the same mentor at Chesapeake Farms agricultural demonstration area on
the Eastern Shore of Maryland. Eveland submitted his findings to the Board, with select Board members
believing that this discovery would spell the end of the three biologists’ tenure with the agency, would end their
anti-deer agenda, and would end the deer-reduction program. However, as Eveland was later told by a
Commissioner, the Board lacked the courage to deal with the issue and chose the easiest path which was to
ignore the problem. Following is the email that Eveland submitted to the Board of Commissioners, and a brief
description of his findings. A detailed account is available upon request.
Sent: Friday, October 28, 2011 9:42 AM
Subject: PGC's Chesapeake Farms Connection
Commissioners,
Based on rumors circulating within the Pennsylvania Game Commission, I have investigated and uncovered a
circumstance of great concern to sportsmen and those within the Commission who still believe in the original
intent and chartered mission of the agency as described under Title 34 -- The Game and Wildlife Code. These
findings leave no doubt that the deer reduction program was an orchestrated event that was intended to
advance a special-interest agenda -- an agenda that is not in the interest of sportsmen nor recreational hunting
- - and that all three deer biologists on the staff were hand-picked to advance this agenda. There is also no
doubt that these staff members, those who hired and supervise them, and those within the agency who continue
to facilitate this anti-deer, anti-sportsmen, and anti-recreational hunting agenda are in direct violation of State
Law - - Title 34, Section 322(c)(13).
I leave it to the readers of this document, PGC's Chesapeake Farms Connection, to decide for themselves how
this circumstance unfolded and how it should be addressed. Nevertheless, it is needless to say that much is
askew, and there is much for which to be concerned, within the confines of the Pennsylvania Game
Commission.
John Eveland
Brief description of findings. Following Gary Alt’s resignation, in order to continue the assault on the deer
herd PGC replaced Alt (PGC’s deer management director) with a three-member deer team comprised of three
North Carolina State University students who had each received their training on a 5-square-mile agricultural
demonstration area on the Eastern Shore of Maryland called Chesapeake Farms. There, they were trained not as
conventional wildlife biologists who view deer as a valuable natural resource, but, instead, in methods to reduce
potential impacts of deer on agriculture. PGC’s chief of wildlife management (who was one of the three
original green-certification/deer-reduction architects) hired these three people as PGC’s three-member deer
team – not to promote responsible deer and habitat management, but to expand their deer-reduction training
from the 5-square-mile Chesapeake Farms agricultural demonstration area to a statewide level in Pennsylvania.
It should be noted:
(a) The three-member deer team redesigned PGC’s 10-year deer management plan in order to serve their
personal agenda instead of the Commission’s Legislative mission as directed in Title 34. In the first paragraph
of the first page of their 150-page deer-management plan, the trio wrote: “Balancing white-tailed deer impacts
is the fundamental issue affecting a majority of Pennsylvania’s deer management decisions.” While this is the
self-imposed goal of the three-member deer team and some of PGC’s upper staff, again, it is not the Legislated
mission of the Game Commission. If this agenda had been stated prior to the year 2000 and before the onset of
the current forestry and environmentally sensitive culture of the PGC, the responsible party would have at the
very least been held accountable and reprimanded. It represents conflicting values of over 100 years of
Commission actions, and remains in violation of Title 34 which directs PGC “to serve the interest of sportsmen
for recreational hunting.”
(b) In the August 2012 issue of the Pennsylvania Game News, one of the three-member deer team (Jeannine
Fleegle) wrote an article entitled “Enough”. In it she compared sportsmen who ask for more deer to children
throwing a temper tantrum in Target because they want a new toy, and referred to herself and the Commission
as the responsible adult who vetoes this request. Quoting Ms. Fleegle, “The adult in this situation has two
options: Yield to this basic form of blackmail, thereby reinforcing the behavior and encouraging future
blackmail attempts, or endure the pain of their reasonable decision to teach one of life’s most unpleasant
lessons. In the immortal words of the Rolling Stones, “You can’t always get what you want.”
She continued in the Game News article: “It was time to stop the dilly-dallying. In addition to raising
allocations, a 2-week concurrent buck and doe season was instituted. Things can’t change. Doctors still treat
with leeches, don’t they? So the Commission once again said no to demands calling for more deer as it stood
in the midst of countless blue balls.”
This is the unfortunate PGC attitude that has caused years of frustration for sportsmen, has led to two decades of
severe deer and wildlife mismanagement by the Commission, and has resulted in over a billion dollars of social
and economic impacts to the Commonwealth each year.
(c) In another December 2017 article by the deer team (Jeannine Fleegle) entitled “Biology is Messy”, she
wrote: “The hate and loathing I experience this time of year (deer season) has nothing to do with hunting.
There is nothing wrong with a pile of deer heads. Why? …one less deer on the landscape. How can I make
such a bold statement? I am a non-hunter! Other than the smell and the occasional bulging eyeball, I have
never been offended by a deer head. If you like trees and flowers and birds, then be thankful for that pile of
deer heads.” Again, this is the attitude of disrespect for deer and sportsmen by PGC personnel who are in
charge of managing our Commonwealth’s state mammal and associated multi-billion-dollar outdoor industry.
For nearly two decades the PGC and its three-member Chesapeake Farms deer team have been able to dictate to
sportsmen, legislators, and the citizens of the Commonwealth whatever are their personal wishes with impunity
and without regard for the agency’s official legislated mission as per Title 34. Therefore, the Commission’s
three-member deer team was not hired to serve the interests of sportsmen nor the Commission’s Title 34
mission. They were hired as anti-deer ideologues to permanently reduce the Commonwealth’s deer herd. This
they have achieved. (See Appendix E.)
Section 13. PGC’s deer-management program is not based on sound science. PGC’s deer, wildlife
resources, and forest and habitat programs are politically motivated and have little basis in science. This is the
reason that HB 1483 was designed – to return sound science and responsible wildlife management policies to
Pennsylvania.
After having conducted its intensive and nationally unprecedented 5-year reduction of the deer herd from 2000-
04, and after the failed 2006 DCNR/PGC extensive browse survey that precipitated the retirements of PGC’s
Gary Alt and DCNR’s Merlin Benner, PGC’s newly hired, 3-member, Chesapeake Farms deer-management
team decided that they should articulate a new justification for the agency’s deer-reduction action. Three new
goals were subsequently concocted and listed as being the reasons for herd reduction: (1) to improve the health
of deer, (2) to improve the health of the forest and specifically to increase seedling regeneration of red oaks, and
(3) to improve biodiversity (the numbers and diversity of wildlife, wildflowers, and native shrubs). It was
supposed that all three of these poor and declining wildlife and forest health issues were being caused by an
over-abundance of deer, and, therefore, PGC was justified in permanently reducing the herd in order to restore
health to the forest ecosystem.
(a) Regarding deer health, a 9-year after-the-fact embryo-count study by PGC discovered that deer were not
ever in poor health but had been in good to excellent health in every one of the 22 wildlife management units
throughout the state. According to PGC metrics, “1.50 embryos per adult female deer represents a healthy deer
population”. An average embryo count below 1.10 per adult female represents a population that is in poor
health. During the 9-year study, average annual embryo counts ranged from 1.51-1.61 embryos per adult
female, with a 9-year average of 1.57. The 9-year average for the 22 WMUs ranged from a low of 1.44 in
WMU 3B to 1.84 in WMU 5D. Therefore, based on deer health, PGC had decimated the herd under a false
assumption that deer and the deer population were in poor health.
(b) Regarding forest health and regeneration, a 2015 report by the Legislative Budget and Finance
Committee indicated that following deer reduction, regeneration did not improve on any of the 22 WMUs
throughout the state. This indicated that deer had not been at fault for low rates of seedling regeneration, and it
has been subsequently determined that aging forests with tightly closed tree-top canopies were responsible for
diminishing seedling regeneration. Furthermore, a comprehensive DCNR study in 2006 discovered that only
4% of forest tree seedlings were classified as heavily browsed by deer, while 96% were classified as non-
browsed, lightly browsed, or moderately browsed. About 68% were listed as not being browsed at all. While
this DCNR report could have been devastating for PGC’s deer-reduction program, unfortunately the report was
not widely distributed nor discussed with legislators and sportsmen.
Additionally, a decades-long Penn State study that was conducted by forest hydrologist Dr. William Sharpe
discovered that in addition to closed tree-top canopies that prevented sunlight from reaching the forest floor, the
lack of red oak seedling regeneration was being caused by increasing levels of acidity in soils from acid
precipitation. PGC had staked its reputation and justification for decimation of the deer herd on over-browsing
by deer and claimed that the loss of red oak seedlings to deer overbrowsing was allowing less valuable red
maple seedlings to replace the more valuable red oaks. Dr. Sharpe dispelled PGC’s claim, stating that red oaks
are less tolerant of acidic soils than red maples, and so the oaks were being replaced by the maples as soils
became more acidic. In addition, he stated, that other Penn State studies indicated that deer preferred eating red
maples over red oaks. Furthermore, large oak trees were dying from the tops down because of acid rain, and
unless deer were shinnying up the trees and eating them from the tops down, that deer were not responsible for
the decline of red oaks – the most valued timber crop of DCNR and PGC.
A retired Chief of PGC’s Forestry Division wrote to the agency’s board of commissioners: ”I am concerned
AND angered by the mismanagement of the deer herd in PA under the guise of biodiversity. A feigned lack of
forest regeneration caused by deer was a pretext used to correlate and establish such a fact, which, in fact,
never existed. Research by Penn State professors show acid rain, rodents, ferns, et. al. have more impact on a
lack of new regeneration than deer. I saw this happening during my career as a forester, repeatedly. This
information was provided to the Commission by several Penn State staff and ignored while I was working. It is
time for serious effort to elevate the number of deer or for what reason is a PGC relevant!”
Furthermore, the Kinzua Quality Deer Cooperative (KQDC) was a 10-year project to reduce deer on 74,000
acres (116 square miles) in and around the Allegheny National Forest including ANF and private landowners
such as Kane Hardwoods (a Collins timber company) and other timber and forest products companies. In 2010,
after completion of the 10-year deer-reduction project, a review of the KQDC Report concluded: “It looks like
even with reduced deer numbers they can’t get any regeneration and the predators are giving the awns trouble.
Forest regeneration has been disappointing. One unanswered question is whether results would be different
with less forest canopy blocking light to the ground.”
Therefore, based on forest health and regeneration, PGC had decimated the herd under a false assumption that
deer were the cause of poor seedling regeneration. It is evident that deer reduction was not based on science,
but, instead, on politics.
(c) Regarding biodiversity, a 10-year U.S. Forest Service study discovered that after 10 years of dramatic herd
reduction, the densities and diversity of tree seedlings and wildflowers had not changed. In addition, instead of
PGC’s programs improving habitat for over 150 species of forest wildlife, scores of wildlife species continue in
a precipitous decline or are in imminent danger because of PGC’s inability to create habitat and solve the crisis.
Furthermore, following are excerpts from the 2017 Winter issue of Fair Chase magazine that were written by
Dr. Duane Diefenbach, Director of the federal USGS Pennsylvania Cooperative Fish and Wildlife Research
Unit, and Professor at The Pennsylvania State University.
“The idea behind (PGC’s) implementing APRs (antler point restrictions) was that reducing deer densities would
be unpopular, but perhaps implementing APRs could be a tradeoff that would be acceptable to hunters - fewer
deer overall but more older bucks with larger antlers. But deer management is more than just meeting
biological objectives. This experiment could have been completely successful from a biological standpoint but
a management failure if the results were not acceptable to hunters. One thing that did change opinions during
the course of our research was the reduction in deer density. As deer densities declined, so did hunter
satisfaction. Before the 2002 hunting season, 34 percent of hunters agreed there were too many antlerless deer
where they hunted. But after the 2004 hunting season agreement declined to 13 percent. Most importantly,
hunter satisfaction is driven primarily by the number of deer observed while hunting. Many studies of hunter
attitudes have noted that…at the end of the day, the positive reinforcement of seeing deer while hunting seems
to be the most critical component to hunter satisfaction.“
As has been learned by Dr. Diefenbach’s research, there is more to a successful wildlife management program
than simply biological science, such as the social (and economic) consequences of management actions. While
HB 1483 is designed to be fully cognizant of the serious social and economic implications surrounding PGC’s
deer management program, the bill was prepared with the assistance of expert forestry and wildlife biology
professionals. HB 1483’s Forest and Wildlife Advisory Service will house 15-20 highly professional wildlife
biologists and foresters who in addition to conducting those research parameters for which PGC staff is either
incapable or refuses to study, the Service will provide on-going scientific advisory services to the Governor and
General Assembly to assure the responsible oversight of PGC and to guarantee PGC accountability to the
legislature, sportsmen, and the 12.8 million citizens of the Commonwealth.
Section 14. A Perfect Storm: PGC and DCNR designed a doomsday scenario to virtually exterminate
deer. From 2000-04, PGC engaged in a relentless assault on does and fawns. Three deer-reduction
mechanisms were deployed: (1) extremely high antlerless license allocations, (2) predation, and (3) antler
restrictions.
(a) The Impact of High Antlerless License Allocations. From 2000-04, antlerless licenses were issued at
levels far exceeding impacts expected by sportsmen and legislators. Although members of PGC's Board of
Commissioners privately stated their wish to reduce the herd to a target goal of only 5-6 deer per square mile
(dpsm), PGC admitted to having overshot this targeted number -- leaving only 1-2 dpsm in some areas. PGC
privately stated, "We've literally exterminated deer in some areas and still regeneration hasn't changed." From
2000-04, nearly a half-million deer per year were reportedly harvested. Of this total, an average of 308,758 per
year were does and fawns. Therefore, PGC claimed to have harvested about the same number of does and
fawns per year from 2000-04 as the total number of deer annually harvested before and after this reduction
period. Exceedingly high annual numbers of antlerless licenses are still allocated to this day, 18 years later,
with no indication that the agency will ease the extreme hunting pressure on the herd, and with no concern for
the board of commissioners to intercede.
In addition, DCNR annually lobbies the Commission to not only continue high annual allocations, but
especially to continue providing DCNR with high numbers of DMAP permits for increased killing of does and
fawns on State Forest Lands. After acquiring and reviewing DMAP harvest records at the request of a
concerned DCNR employee, it was learned that harvest success has declined from 3-4 permits per harvested
doe to 9-12 permits being required to harvest a doe – indicating the dramatic decline in the deer herd on State
Forests. Nevertheless, DCNR continues to not only lobby PGC to maintain the high number of DMAP permits,
but urges PGC to increase the number of antlerless tags each year. Since inception of the DMAP program, PGC
has seldomly refused DCNR’s request.
(b) The High Impact of Predation. A PGC/Penn State study in 2000-01 indicated that 22.5% of the total fawn
crop succumbed to predation – about 11% each by bears and coyotes and 1% to bobcats. For decades the bear
population has remained relatively stable at 20-25 thousand bears, and it appears that prior to 2000 the deer
population had been able to cope with the roughly 11% fawn loss attributed to bears. However, it is estimated
that the coyote population has rapidly increased from the time of this study nearly two decades ago to as many
as 250,000-500,000 today. The increasing impact by coyotes is impeding the recruitment capacity of the herd
to grow and possibly even to remain stable.
Other studies from nearby northeast states indicate that coyote predation throughout the East currently accounts
for 50% of fawn deaths, while in the Southeast coyotes inflict up to a 75% early impact on fawns. The
Southeast study concluded that when combined with doe hunting, deer populations are unable to sustain
themselves in the face of such heavy coyote predation. A 12-year Quality Deer Management Association study
confirmed that fawn predation in northern-tier Pennsylvania has increased from 25% over a decade ago to as
high as 50-75% today. In contrast to Southeast biologists who recognize the seriousness of the situation, the
leader of a proposed $3.9 million PGC/Penn State predation study responded, "Only an average of one in two
(fawns) survives its first three months of life. Regardless, this number of fawns that survive generally is
adequate to sustain nearly all populations." The accuracy of this statement, however, is questionable.
Coyotes are ubiquitous within Pennsylvania, and the rapidly growing coyote population is not only impacting
fawn survival and the deer herd, but also represents a dramatic deterrent to the health of virtually every other
mammal, bird, reptile, and amphibian in the state. However, coyotes are not the latest in PGC’s
mismanagement of predator/prey relations in the state. Within the past three decades PGC has introduced and
distributed fishers throughout the Commonwealth. Fishers are large, weasel-like predators that, like coyotes,
prey on virtually any wild animal. Primary prey of fishers includes snowshoe hares and porcupines. PGC has
expended significant time and resources toward increasing snowshoe hare populations across the state. In
addition, PGC has recently adopted a new hunting season on porcupines, thus limiting the number of porcupines
and refocusing fishers toward other wildlife such as snowshoes, grouse, and fawns. These actions bring into
question the competence and motivations of the PGC in fostering such new predators as fishers.
(c) The Impact of Antler Restrictions. During Gary Alt's statewide tour to convince sportsmen that the deer-
reduction program would be temporary and limited, PGC used the prospect of larger-antlered buck as an
incentive (a "carrot") to entice sportsmen to accept reduction. However, a DCNR report revealed a more
sinister reason for the antler-restriction policy: "Increased restriction for antlered bucks made it harder to
harvest a buck so hunters were more apt to harvest an antlerless deer instead." Additionally, in decades prior to
the herd-reduction program (under the traditional, scientific "maximum-sustained-yield" method of deer
management) about 90% of the overwinter herd consisted of does and fawns – thus maximizing the herd's
growth potential. However, under the new antler-restriction policy, up to 40% of the overwinter population is
designed to consist of adult buck, thus decreasing the productivity of the herd.
(d) Conclusion. Along with predation, antler restrictions represent a biological "insurance policy" for PGC to
prevent herd growth and maintain low deer population levels even if their own Board or the Legislature would
mandate lowering the number of antlerless hunting permits. If PGC biologists have been aware of the
extraordinarily high impact of combined hunting, predation, and antler restrictions over the past 18 years, then
they are guilty of selective ignorance and deceit in not informing their own Board of Commissioners,
sportsmen, and legislators, and for permitting the relentless assault to occur. If PGC biologists were unaware of
this "Perfect Storm", then they are just as guilty of incompetence.
Section 15. Pennsylvania is ranked #1 as the worst hunting state in the nation. Quoting the national, online
magazine WideOpenSpaces:
“Truth be told, you could probably hunt with a hand grenade and still strike out in one of these 8 worst states.
A lot of states are doing things right when it comes to deer and deer hunting. However, a few states are on a
stark downward trend. Good old Penn is the unanimous winner as the worst state to not only bowhunt, but
just really hunt in general. To make matters worse, CWD is spreading.”
PGC has responded by claiming that a national survey indicates that the agency’s deer-management program is
first in the nation. However, PGC fails to note that the survey was conducted by a PGC allied organization, and
that the survey results were based on PGC’s false and highly exaggerated harvest figures. (See Appendix F.)
Section 16. PGC’s wildlife management failures are costing the state $1.2 billion in lost economic activity
and $92 million in lost tax revenue. From the national “Deer Summit 2017” consisting of industry, state and
federal wildlife agencies, and organizations from throughout the country, the Summit concluded:
“We all know that deer drive the financial backing of our state wildlife agencies. Losing deer, or losing deer
numbers, would mean a financial disaster with the loss of funds used to manage all wildlife. It’s that
simple.”
In 1998, PGC changed its wildlife management policy to comply with the forestry and environmental special
interests of DCNR. This new DCNR/PGC “ecosystem management” philosophy is focused on preserving old-
growth forests, native shrubs, and wildflowers at the expense of the deer herd, grouse, wildlife habitat, sport
hunting, 150 other species of wildlife, the multi-billion-dollar outdoor industry, and millions of the state’s
citizens. (See Appendix F.)
The magnitude of the biological, social, and economic impacts has been egregious and unacceptable. PGC’s
mismanagement of deer, wildlife, and forest resources is causing the following negative impacts:
(a) Collapsed Deer Herd. PGC caused the near-biological collapse of the statewide deer herd. During a 5-year
period from 2000-2004, PGC killed 2,500,000 deer – reducing the herd from a healthy 1,500,000 deer by 60%
to only 600,000 animals. According to Commissioners, in some regions the herd was overshot to an unhuntable
number, leaving only 1-2 deer per square mile. From 2005 to the present, PGC has attempted to stabilize the
herd at these permanently reduced numbers using high annual allocations of antlerless licenses and DMAP
permits.
(b) Critical Habitat Loss. Wildlife habitat over the combined nearly 6,000-square-mile system of public game
and forest lands is deteriorating at an unprecedented rate, with little intension by PGC to create new critical
habitat.
(c) Declining Wildlife. Over 150 species of wildlife are in rapid decline or in imminent danger because of poor
and declining habitat. Grouse are at a 50-year low with no end to their decline in sight. Some bat populations
are nearing extinction.
(d) Empty Cabins. Family cabins and hunting camps stand empty due to the lack of deer and other wildlife.
(e) Declining Sportsmen. According to the Legislative Budget and Finance Committee (LB&FC), as of 2010
117,000 sportsmen had quit hunting. As of 2016, a total of 270,000 hunters had been effectively lost as hunters
and economic generators due to the lack of deer and failed hunting regulations.
(f) Economic Disaster. According to the LB&FC, as of 2010 the impact in lost Commonwealth economic
activity was calculated to be $501.6 million per year. The Cameron County Chamber of Commerce referred to
PGC’s deer program as “economic suicide for the county. Most family businesses that have not closed are
down 50-60%.” This is a microcosm of the economic impacts especially to rural communities. As of 2016, the
economic impact to the Commonwealth had increased to $1.16 billion per year, with a cumulative impact of
$10 billion.
(g) Lost Tax Revenue. According to the LB&FC, as of 2010 the impact in lost tax revenue was $40 million per
year. As of 2016, lost tax revenue had increased to $92.5 million per year.
(h) Lost Jobs. PGC’s failed deer and wildlife programs may have cost over 13,000 jobs to rural communities.
(i) PGC Budget Deficit. PGC is calculated to be losing $8.1 million per year in lost hunting-license fees. Note
that PGC is requesting a license-fee increase of $8M. Considering that PGC’s deer program has caused a lack
of deer with resulting loss of hunters, PGC has caused its own budget deficit.
(j) Causing CWD. Based on a 10-year study by the University of Wisconsin, PGC’s failed CWD policy is
increasing the frequency of infection and rate of spread of the disease and threatens to destroy deer and elk
herds.
(k) Zero Trust. PGC has destroyed its trustworthy relationship with sportsmen, legislators, and citizens.
Section 17. PGC’s impact to ruffed grouse -- the Commonwealth’s State Bird. Collapsing Pennsylvania’s
deer herd and related outdoor industry along with mismanagement of forests and wildlife habitat are not the
only impacts from PGC’s failed policies. A May 2017 article in the Pittsburgh Post-Gazette entitled “Ruffed
grouse population is threatened” stated: “The Game Commission’s 2017 report to the General Assembly
reported that grouse populations had fallen to their lowest level in 50 years.” According to PGC Wildlife
Biologist Lisa Williams in a Game News article: “This year, the American Bird Conservancy identified early
successional forests of the Northeast as one of the Top 10 threatened habitats in the United States. As a result
of the loss of young forests, more than 30 species of wildlife that rely on this habitat type in Pennsylvania are
declining.”
A Pittsburgh Tribune-Review article entitled “Future is Ruff” stated: “Sightings (of grouse) this year were the
fewest ever, according to PGC’s Lisa Williams. In 1993, according to PGC figures, there were 242,397 grouse
hunters. By 2014, the ranks of grouse hunters fell to 50,925. That’s a 79% drop. Turkey hunters fell 12%.
Pheasant hunters declined 60%, squirrel hunters 61%, and rabbit hunters 79%. The 1993 grouse harvest was
272,690. In 2014 it was 34,848. That’s an 87% difference. It has gotten to the point where more people today
hunt the lowly groundhog than grouse.”
“That is not how things have to be”, said Dan Dessecker, director of conservation policy for the Ruffed Grouse
Society. “There are states in the upper Midwest and New England where grouse remain plentiful. Not
coincidentally”, he said, “they also have the best grouse habitat. This is not rocket science”, Dessecker said.
“If you have young forests, you will have grouse. Pennsylvania doesn’t.”
Pete Sussenbach, director of the bureau of habitat management for the Game Commission said, “Right now, we
are heavily skewed toward the 80 to 120-year-old age class. There’s just not a heck of a lot of those early
successional forests out there. You’ve got to provide an abundance of good habitat. A dot of it here and there
isn’t going to do much. Habitat crews statewide already are shorthanded, and the problem is only expected to
get worse”, Sussenbach said.”
Recently, the Ruffed Grouse Society published the “President’s Message” by John Eichinger, President and
CEO of RGS, entitled “Stay Focused on Habitat”. Quoting from the president’s message: “Pennsylvania’s
population monitoring indicates that regions with high-quality and abundant habitat show a strong grouse
population recovery between WNV (West Nile Virus) peaks, and flush rate data from Wisconsin, Minnesota and
Michigan appears to support this connection. These preliminary findings seem to make sense and reaffirm the
crucial role habitat plays in bird health, disease resistance and population resilience. We, as hunters, should be
disappointed that our Pennsylvania grouse season was cut short as PGC temporarily shortened the 2017-2018
season based on the effect of WNV. We should be even more disappointed because the lack of high-quality and
abundant young forest habitat made grouse vulnerable to disease in many parts of Pennsylvania in the first
place (where the ruffed grouse is the state bird!). Stay focused on the bottom line now…young forest habitat.”
At PGC’s current rate of habitat improvement for grouse, deer, and many other game and nongame forest
species, it would take the Game Commission 100-200 years to accomplish what HB 1483 would achieve in 10-
15 years.
Section 18. PGC’s impact to wildlife resources. According to the Ruffed Grouse Society and State of Ohio,
at least 60 of species of wildlife are in precipitous decline and will continue to decrease in numbers without
direct intervention and habitat enhancement. In addition to deer and grouse, about 150 wildlife species are
either in decline or in imminent risk in Pennsylvania due to the continuing loss of early-successional habitat – a
decades-long management failure. While other states including Ohio, Arkansas, Minnesota, New York, and
West Virginia are taking urgent actions to address this ongoing crisis, Pennsylvania continues to ignore broad-
scale habitat enhancements on approximately 1,500,000 acres of state game lands and throughout the nearly
4,000,000 acres of combined state game lands and state forests.
The Game Commission’s failure to provide high-quality and abundant young forest habitat ignores the
Pennsylvania Constitution’s directive “to wisely manage natural resources for all the people.” An estimated
151 species (41 species of mammals, 84 birds, 18 reptiles, and 8 amphibian species) are at risk. This list does
not include the many dozens of beneficial insects, especially at-risk pollinators such as bumble bees, honeybees,
and moths and butterflies. While DCNR’s forestry policy has been to fence new cuttings from usable habitat
for large species of wildlife, especially deer, until only the past year or two PGC has followed DCNR’s lead by
fencing newly created habitat from full use as wildlife habitat. Two years ago, PGC’s executive director stated
that PGC was considering changing its timbering and forest management policy from benefitting trees to
focusing on benefits for wildlife. Such a revelation for PGC is egregious in the face of declining wildlife.
While PGC often blames the agency’s slow pace of habitat enhancement on low-priced timber markets, other
states, such as Arkansas, have made it clear that timbering operations are intended to benefit wildlife regardless
of the existing market prices for timber. (See Appendix F.)
Section 19. Lost deer and lost hunters result in a Socio-Economic disaster. A 2012 Legislative Budget and
Finance Committee (LB&FC) report indicated that from 2000 to 2011 the number of Pennsylvania hunters had
dropped from 1.05 million to 933,000 – a loss of 117,000 hunters between 2001-11. While the PGC reported to
LB&FC that the size of the deer herd had declined from 1.5 million to 1.2 million during this time, this
politically-motivated claim was far from accurate. Scientific studies indicate that between 2000 and 2004 the
herd had been reduced by 60% from 1.5 million to only about 600 thousand, and that PGC had maintained the
herd at these low levels thereafter.
Quoting the LB&FC report: “The number of general hunting licenses sold by the PGC has also fallen, from
1.05 million in 2001 to about 933,000 in 2011. Nationally, however, hunting participation increased by 5
percent between 2001 and 2011. The U.S. Fish and Wildlife Service estimates average 2011 expenditures per
hunter at $2,484. The decline in hunter participation between 2001 and 2011 therefore represents a potential
loss of $285 million in direct economic activity.”
In 2017, the LB&FC’s executive director notified John Eveland that the $285 million annual impact represented
just direct spending, and that the actual total economic impact was calculated to be $501.6 million per year.
Further, as of 2010 the corresponding loss in annual tax revenue would be $40 million -- $25 million in state
taxes and $15 million in local taxes.
According to the latest 5-year report in 2013 by the American Sportfishing Association which collects and
publishes hunting and fishing data under a grant from the U.S. Fish and Wildlife Service: “In short, datasets
show a recent slight increase in the number of hunters (nationally).” A USF&WS bar-graph figure in the
report showed an increase in hunters from 2000 to 2011. However, Pennsylvania did not fare so well. In an
associated table depicting hunting participation by state between 2006 and 2011, Pennsylvania ranked 45th
in
the percentage of hunters lost to the sport. Placed in perspective, 28 states were listed in the green area with
increases in the number of hunters ranging from a 4% increase in Tennessee to a 96% increase in Alaska. Five
other states were listed in the yellow (caution) zone with relatively stable numbers of hunters from 0% to -3%.
Finally, there were 17 states listed in the red zone ranging from -4% in West Virginia (ranked 34th
) to Maryland
at -48% (ranked 50th
). According to the National Survey data, from 2006-11 Pennsylvania had a -25% change
in hunter participation – a loss of 933,000 resident hunters in 2006 to 699,000 resident hunters in 2011.
In 2017, a Commission news release announced that in 2016 only 550,000 hunters were afield during the first
day of the rifle buck season – a reduction of 200,000 from 750,000 six years before. While the Commission
claims that the precipitous loss of hunters (that has coincided with their deer-reduction program) is the result of
outside influences from youth soccer to video games, most sportsmen claim otherwise. An August 30, 2012
Outdoor News article entitled “Pennsylvania lags in sales of hunter licenses” stated: “While the number of
licenses rose nationally by 9% over the past five years, they dropped in Pennsylvania, according to a
preliminary report from the U.S. Fish and Wildlife Service.” (See Appendix G.)
PGC has also attempted to explain the loss of 200,000 hunters during rifle deer season on archery hunting,
claiming that between 2010 and 2016 these hunters became crossbow hunters. However, an inspection of
license sales indicated an increase of only about 50,000 hunters during this period due likely to the legalization
of crossbows, leaving about 150,000 hunters lost and unaccounted.
In addition to the loss of hundreds-of-thousands of hunters from 2000 to 2017 and an estimated cumulative loss
of $10 billion in economic activity since inception of the deer-reduction program in 2000, this loss of hunters
represents a serious and growing threat to our Second Amendment rights.
Section 20. Sportsmen hate PGC’s deer-management program. In January 2016, a House Game and
Fisheries Committee hearing was held regarding pending deer management legislation. At that time, three
attending Game Commission representatives, including Bryan Burhans and Wayne Laroche, stated:
• that the Commission's deer-management program was second to none in the country;
• that a majority of hunters are in approval of the program; and
• that the Commission would be making no significant changes to the program.
Therefore, in an effort to determine the validity of the Commission's claim "that a majority of hunters are in
approval of the agency's deer-management program", at the request of legislators a 72-hour telephone survey
was conducted in mid-April 2016. Those who were surveyed were asked if they approved of the Commission's
current deer-management program, or if they were in favor of deer-management reform.
The survey included 110 sportsmen clubs and businesses from the central and northern portions of the state. A
sampling of five county chambers of commerce representing roughly 2,000 businesses were only listed as five
(5) contacts on the survey. No individual sportsmen were called, only sportsmen clubs with most ranging from
about 1,000 to 10,000 members. Some were much larger. Of the 110 contacts, only one call resulted in favor
of PGC’s deer management program (and even that was due to a political connection with the agency). This
represents only a small microcosm of the many thousands of businesses and many hundreds of thousands of
sportsmen who want dramatic deer management reform. The survey counted about 700,000 sportsmen who
want reform. Their comments were compiled, and the animosity for the Commission cannot fully be described,
in that many of the comments by club presidents and business owners were so laden with expletives that they
were omitted from the report. It is a demonstration of the overwhelming degree of dissatisfaction with the
Commission's deer-management program, and the desire for legislative reform. (See Appendix G.)
Section 21. PGC’s deliberate violation of State Law. While PGC may have been in violation of state laws
including ethics violations, conflict of interest, inappropriate use of funding, violation of the public trust, and
abuse of power for the past several years, since 2000 the Commission has been in deliberate violation of two
state laws: Title 34 and The Pennsylvania Constitution.
(a) Violation of Title 34 (Game and Wildlife Code). Title 34 represents the legislatively chartered mission of
the agency. As is specifically directed: “Title 34: Section 322. Powers and duties of the Commission. (c)
Specific powers and duties. In order to administrate and enforce this title, the Commission through proper
action shall: (13) 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.”
Paraphrased. It is the duty of the Commission to serve the interest of sportsmen for recreational hunting.
Discussion. In PGC’s official 10-year deer-management plan (Management and Biology of White-tailed Deer
in Pennsylvania 2009-2018) that was written by PGC’s three-member deer team (Christopher Rosenberry, Brett
Wallingford, and Jeannine Fleegle), in the first paragraph of the first page of this approximately 250-page
document the three PGC employees wrote: “Balancing white-tailed deer impacts is the fundamental issue
affecting a majority of Pennsylvania’s deer management decisions.”
Herein, it should be stated that: “NO IT IS NOT!” Pennsylvania state law as directed in Title 34 specifically
states that PGC’s mission is, “to serve the interests of sportsmen for recreational hunting”. Title 34 does not
state that PGC should or has the authority to arbitrarily supersede the law and dismantle the statewide herd at its
discretion in order to reduce impacts that are real, or in this case imagined, by employees of PGC.
This official attitude explains how such a devastating assault could occur to the Commonwealth’s deer herd. It,
also, represents PGC’s admission to the agency’s direct and deliberate violation of Title 34. PGC’s goal as
stated in the agency’s 10-year deer-management plan has been to reduce deer impacts by reducing deer – as the
three-member deer team had been trained to do at Chesapeake Farms. They have accomplished their goal in
violation of Title 34 (Section 322(c)(13)), and at great expense to sportsmen and recreational hunting, to family
businesses and rural communities, to the statewide economy, to deer and wildlife resources, and to the general
outdoor-loving public.
When asked by the Governor’s Council for Hunting, Fishing, and Conservation what role hunters play in deer
management, PGC’s former executive director, Carl Roe, responded: “Hunters have no role in deer
management.” Additionally, in a December 2017 article by Jeannine Fleegle entitled “Biology is Messy”,
PGC’s deer biologist wrote, “The hate and loathing I experience (for deer). I recently shared a photo of a
happy pile of deer heads on our (PGC) Twitter feed. There is nothing bad about a pile of deer heads. Why? …
one less deer on the landscape. I am a non-hunter! Other than the smell and occasional bulging eyeball, I
have never been offended by a deer head. If you like trees and flowers and birds, then be thankful for that pile
of deer heads.”
This appalling attitude by PGC’s deer team demonstrates their loathing for deer and desire, if able, to eliminate
deer from the Pennsylvania landscape to the extent possible. It is a deliberate violation of Title 34.
(b) Violation of the Pennsylvania Constitution. As directed in the Pennsylvania Constitution: “Article 1.
Declaration of Rights. Section 27. Natural Resources and the Public Estate. 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.
Pennsylvania’s public natural resources are the common property of all the people, including generations yet to
come. As trustees of these resources, the Commonwealth shall conserve and maintain them for the benefit of all
the people.”
Paraphrased. The Commonwealth shall wisely use natural resources for all the people.
Discussion. For the past two decades, PGC has been unwilling to create habitat for scores of wildlife species
because it would also represent habitat improvements for deer. As forests have grown to an average age of 80-
125 years, they have matured beyond their most productive years for many wildlife species, with closed tree-top
canopies preventing sunlight from reaching the forest floor. As a result, understory vegetation has declined
along with the populations of 151 wildlife species that rely on early-stage forests and dense undergrowth. PGC
had mistakenly blamed the lack of forest understory growth on deer and used this circumstance to justify their
assault on deer. While PGC attempts to vilify deer, habitat and wildlife populations continue to decline. As an
example, grouse have reached an all-time low and are at risk of near extermination as the impacts of a disease
(West Nile virus) increase due to declining vigor as a result of the loss of habitat. PGC is, therefore, not only
ignoring the Constitutional directive, but is exacerbating the decline of deer, grouse, and about 150 other game
and nongame wildlife species. Instead of “wisely managing wildlife resources for all the people” as is directed
in the Pennsylvania Constitution, the PGC is devastating wildlife at the personal discretion of a few agency
employees toward satisfying their unscientific and politically motivated personal agenda.
It is evident that PGC does not view deer as a valuable natural resource, but simply as forest vermin to be
eradicated. PGC’s goal is not to manage deer in the best interest of sportsmen nor to wisely manage deer for
use by all the people, but instead to eliminate deer from the Pennsylvania landscape to the extent possible. In so
doing, the agency is responsible for the decline of habitat and demise of 150 species of native wildlife. The
agency is, therefore, in direct and deliberate violation of two state laws -- Title 34 and the Pennsylvania
Constitution.
Section 22. PGC is playing a political game and deceiving legislators. In April 2018, John Eveland was
contacted by a retired high-ranking chief of the Game Commission. For some time Eveland 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. The answer that he received
was shocking.
Quoting the Commission’s former 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.”
This revelation should be enough to end PGC’s ecosystem-management/deer-reduction program and 18 years of
deceit by PGC in which the agency has wrought havoc on the deer herd and sport hunting, caused over a
billion-dollars per year of impacts to rural communities and the Commonwealth’s economy, and is devastating
wildlife habitat for grouse and 150 other species of game and nongame wildlife. But there is more.
In early April 2018, Executive Director Bryan Burhans told the HG&FC that the Commission cut 8,500 acres of
timber for habitat in 2017. Checking PGC’s cutting rates for 2016 and 2015, it was found that the agency had
cut 6,200 acres and 5,000 acres, respectively, in those years. These numbers represent 0.33% (1/3 of 1%) cut in
2015, 0.41% cut in 2016, and 0.57% (1/2 of 1%) cut in 2017 of their 1,500,000-acre state game lands holdings.
At that rate, the Commission is cutting only 1% of their forest holdings every three years.
The retired chief further stated:
• “Fire is beneficial, but pales in comparison to timber cuts for wildlife.”
• “The lack of regeneration is being caused by acid rain and shaded forests – not by deer.”
He believes that PGC had reduced the deer herd by over 60%, and that their high annual harvest claims are
exaggerated. He concluded the conversation by saying:
• “They’re playing politics. They’re playing the same game to get a license increase as the guy in the Fish
Commission tried to do.” They just need to do their jobs like we did years ago.”
This information should solidify the following points:
(a) The Game Commission has, in fact, been deceiving Legislators in an attempt to gain a license-fee increase.
(b) In refusing to cut timber so as to perpetuate PGC’s ruse, the agency has been willing to permit deer, grouse,
and over 100 species of wildlife suffer and decline. According to PGC Executive Director Bryan Burhans in his
April annual report to the HG&FC, “We live by our mission to manage Pennsylvania’s wild birds, wild
mammals, and their habitats for current and future generations.” It is true that the Pennsylvania Constitution
directs the responsible management of Pennsylvania’s wildlife for all citizens. However, it appears that the
PGC cares less for 151 species of forest wildlife and their habitat than in perpetuating a ruse toward deceiving
the Joint Legislature into approving a license-fee increase. The Commission should not be rewarded for their
actions. Instead, the agency should be held accountable for being in violation of the Public Trust and the
Pennsylvania Constitution.
(c) Passage of HB 1483 would resolve the crisis, create more wildlife habitat for deer, grouse, and 151 species
than PGC plans for decades, and provide a mechanism for the Legislature to oversee the PGC going forward.
Section 23. Should PGC be rewarded for what it has done? On top of PGC’s wish list is for passage of a
new law that would provide the agency with a license-fee increase, or better yet, for passage of another bill that
would grant PGC the ability to raise hunting license fees at their discretion – to any degree and at any time --
without regard for oversight by the Legislature. In this regard, there are two considerations that come to mind.
First, PGC has wrought billions-of-dollars of biological, social, and economic impacts to the Commonwealth
over the past 18 years and should hardly be in consideration for a financial payday for gross mismanagement of
wildlife resources and flagrant violations of the agency’s charterred mission and state law. Secondly, financial
analyses indicate that PGC’s claimed budget deficit of $8 million was caused by their own mismanagement of
deer and wildlife resources, in that the loss of hunters is costing the agency over $8 million per year. PGC,
therefore, has created its own budget deficit.
In addition, in a recent Game News article entitled “Deer plan scores well internationally” and subtitled
“Experts say Game Commission’s deer management has the right stuff”, PGC touted a deer management
award, writing that Simon Fraser University acknowledged the agency’s deer plan as one of North America’s
best. When one’s decision is based on data provided by the PGC, then this award might be considered about as
valid as DCNR’s annual Green Certification award (see Sections 3-5 of this report). It is unlikely that a few-
hundred-thousand former hunters would have granted PGC this award.
Recently a brief internet survey was conducted over the course of a very few weeks asking if Pennsylvania
citizens wished for legislative action to resolve PGC’s mismanagement of deer and wildlife resources.
Hundreds of comments accompanied the 1,500 signatures on the petition. One comment seemed to be
representative of the disgruntled sportsmen and citizens:
“The PGC and DCNR employees who perpetrated this hoax should be held accountable. Termination of their
employment and loss of their pensions would not be too severe. Those already retired should be sued for
damages in civil court. Our legislators must make it perfectly clear to present and future employees that
incompetence and cronyism when dealing with our natural resources will not be tolerated”
Section 24. Summary and Discussion. For decades prior to the year 2000, the Game Commission had
operated a traditional deer and wildlife management program that was consistent with every other state in the
nation. Pennsylvania was annually ranked as one of the top two deer-management states in the nation. There
were up to 1.2 million hunters who supported a vibrant outdoor industry that provided thousands of jobs and
billions of dollars throughout rural communities. Wildlife abounded, family cabins and hunting camps were
filled, and millions of citizens enjoyed the wildlife resources of Penn’s Woods.
However, in 1998 DCNR entered into a mutually beneficial, money-generating contract with a German-based
environmental organization (Forest Stewardship Council (FSC)) that presented a unique opportunity to
permanently and dramatically reduce the statewide deer herd. Only three men were directly involved in this
long-term goal of DCNR: (1) the representative of the environmental organization who despised deer and who
operated a Pennsylvania-based deer culling business to eliminate deer from urbanized areas, (2) a DCNR
forester who despised deer and blamed them for deterring forest seedling regeneration, and (3) a PGC chief who
despised deer and blamed them for the loss of habitat for other nongame wildlife. They succeeded in
convincing the governor that deer-reduction was a scientific necessity, and, as a result, over a five-year period
from 2000 to 2004 orchestrated the killing of 2,500,000 deer from a previously stable population of 1,500,000
animals.
The slaughter was so dramatic that PGC admitted in private that they had overshot the herd in some regions to
only 1-2 deer per square mile. It is likely that no other state in the nation would have considered such an action.
The impacts to sport hunting and rural economies soon began to take a toll. DCNR and PGC realized that they
risked losing the support of hunters and legislators if the two agencies could not demonstrate after the fact that
deer were, in fact, demons of the forest and, therefore, that the actions of PGC and DCNR were justified.
Toward this end, DCNR conducted a massive study that covered 88% of DCNR’s 2.4 million-acre system of
State Forests with 47,327 individual plots studied to determine the impact of deer on forest regeneration. The
study was a dismal failure, in that 68% of forest seedlings were not at all browsed by deer, another 21% of
seedlings were only lightly browsed, and only 4% of seedlings and saplings were classified as being heavily or
severely browsed.
At this time, the deer management program should have been swiftly ended, the perpetrators disciplined, and
responsible forest and wildlife managers hired to return to wise management of the Commonwealth’s forest and
wildlife resources. Instead, the study’s conclusion was manipulated toward advancing the DCNR/PGC agenda,
and the study was not widely distributed or otherwise noted. Nevertheless, the two leaders of the study (Gary
Alt as PGC’s director of the deer-management program, and Merlin Benner of DCNR) resigned.
DCNR was determined to maintain the pressure on the deer population and set in place a DCNR Advisory
Council to annually pressure PGC to increase statewide antlerless allocations and increase DMAP permits for
State Forest Lands. Audubon Pennsylvania (led by successive presidents Cindy Dunn and Tim Schaeffer)
assisted in the endeavor. PGC’s Board of Commissioners has annually complied for nearly two decades and
assured unwavering compliance by replacing Gary Alt with a three-member deer-management team that had all
been students at North Carolina State University, and had all been trained on a small, 5-square-mile agricultural
demonstration area on the Eastern Shore of Maryland called Chesapeake Farms. The three were not trained as
conventional wildlife biologists who view deer as a valuable natural resource, but, instead, as forest vermin that
need to be eradicated to the greatest extent possible. They were hired to advance their Chesapeake Farms
training to a statewide level in Pennsylvania and have succeeded in keeping the state’s deer herd at the lowest
number that can be tolerated by sportsmen and the Legislature.
While the Board of Game Commissioners has supported the staff’s goal to reduce deer in order to reduce
impacts that they believe are caused by deer, in private conversations commissioners have lamented not being
able to stand up to the Commission staff, and reluctantly have conceded to PGC’s new mission – an arbitrarily
designed mission by a handful of staff who have no concern with this violation of Title 34 and who have no fear
of oversight and reprisal from the Legislature. When asked what importance sportsmen have regarding deer
management, a recent PGC executive director told the Governor’s Council for Hunting, Fishing, and
Conservation: “Hunters have no role in our deer management program.” The chief of the deer and wildlife
management program stated in private conversation: “I get what I want. I baffle them with b___s___.”
Extensive scientific studies that have been conducted over the past 18 years by Penn State, independent
scientists, the Legislative Budget and Finance Committee, the U.S. Forest Service, DCNR, and the PGC, itself,
have indicated that PGC’s deer-reduction action had no basis in science – with little to no benefits for forest
regeneration, forest health, deer health, or increased biodiversity of plants and animals from wildflowers and
native shrubs to songbirds and myriad nongame species of wildlife. In fact, studies have indicated that PGC’s
mismanagement of forest and wildlife resources are often detrimental to a healthy forest ecosystem and are in
many instances contributing to the decline of scores of wildlife species across the state.
Ironically, these after-the-fact studies have learned that deer were not the culprit in declining tree seedling
regeneration and the decline of understory vegetation as wildlife habitat. The cause has been over-aged forests
that at 80-125 years old have tightly closed tree-top canopies that are preventing sunlight from reaching the
forest floor. In addition, Penn State studies have warned PGC for decades that increasing soil acidity from acid
rain was killing highly valued large red oaks and preventing oak regeneration while less valuable and more acid
tolerant timber species such as red maples were replacing oaks in the forest ecosystem. PGC ignored the
warning.
In short, the two forestry and environmentalist special interests had been mistaken in blaming deer for forest
regeneration maladies, and PGC mistakenly complied with their wishes by overkilling deer from 2000 to the
present with no regard for sportsmen or socioeconomic impacts to the outdoor industry. This represents a
deliberate violation of PGC’s legislated mission – Title 34, Section 322(c)(13). It was initiated without first
conducting a comprehensive cost/benefit analysis which is a standard of industry that is normally undertaken
before commencing any large action. The error was made by the excessive hubris of a handful of men and
continues because the error was so large that it is now impossible to admit the mistake.
In addition, according to ten years of studies in other states, PGC’s CWD management program is so ineffective
that it is encouraging the frequency-of-infection and rate-of-spread of chronic wasting disease. If not
immediately curtailed, the Commonwealth now risks losing both deer and elk herds due to PGC
mismanagement.
Socioeconomic studies by the Legislative Budget and Finance Committee have determined that as of 2010
PGC’s programs were causing an annual economic impact to the Commonwealth of $501.6 million per year,
with an associated impact of $40 million per year in lost tax revenue. As of 2016, these economic impacts had
increased to $1.16 billion per year in lost Commonwealth economic activity and $92.5 million per year in lost
government tax revenue. The cumulative impact over the past 18 years is estimated at $10 billion, with an
estimated loss of 13,500 jobs. These impacts have been most strongly felt throughout rural communities, with
the Cameron County Chamber of Commerce stating that PGC’s deer program is “economic suicide for the
county, and those businesses that remain open are down 50-60%.”
While over a million hunters were afield during the heydays of deer hunting in the 1980s and ‘90s (prior to
PGC’s deer-reduction program that commenced in 2000), a PGC news release indicated that in 2010 there were
only 750,000 hunters left who were afield on the opening day of the rifle deer season, and as of 2016 this
number had declined to 550,000 – a loss of 200,000 in six years. The author was informed that last year’s
opening day had 438,000 deer hunters afield on the opening day.
In addition to the drastic and permanent reduction of the deer herd with associated loss of hunters and
increasing socioeconomic impacts, PGC has refused to address a critical need for more wildlife habitat. For
over two decades, habitat as food and cover for wildlife has been virtually ignored by the PGC and has now
reached a critical point. One of the most productive components of the forest is young, early-stage, seedling-
sapling stands that arise after cutting old-growth forests. PGC’s unwillingness and inability to create adequate
amounts of young-forest wildlife habitat is currently impacting an estimated 151 species of wildlife – from deer
and grouse (the Commonwealth’s State Mammal and State Bird) to songbirds and dozens of other nongame
species that are either currently in decline or at imminent risk. The list includes 41species of mammals, 84
birds, 18 reptiles, and 8 amphibians. In addition, pollinators such as honeybees, bumblebees, and butterflies are
at risk.
Over the past three years, PGC has only cut an average of one-third of one percent of State Game Lands
holdings, while the Ruffed Grouse Society and others are pleading for much more -- up to 10% per year. While
PGC claims that West Nile Virus is the cause of a precipitous decline of grouse, studies in other states disagree,
indicating that with adequate habitat and resulting healthy birds, grouse populations are fully capable of
withstanding the disease and prospering. PGC’s habitat management director stated that Pennsylvania lacks
adequate habitat, is not creating it, and things are only going to get worse.
Not only are deer, grouse, and about 150 other wildlife species in decline or at imminent risk, but also at risk are
the millions of wildlife-loving citizens who recreate in Penn’s Woods and who rely on seeing abundant wildlife.
While hunting camps now stand empty because of the lack of deer, so, too, are family cabins that now are
empty because of the overall lack of wildlife due to inadequate habitat.
With these considerations in mind, a retired PGC chief recently stated that the reason that PGC is not cutting
timber (for deer, grouse, and 150 other species in need) is because: “PGC is playing a political game with
legislators. If they cut timber they’ll make a lot of money and won’t be able to justify a license increase.” It
should also be noted that until about two years ago (spurred by pressure from pending legislation as per HB
1483), PGC’s few cuttings were fenced to exclude deer – a costly process that was intended to value tree
production over deer production, and that was in direct and deliberate violation of Title 34, Section 322(c)(13).
This circumstance also represents a gross and deliberate violation of the Pennsylvania Constitution, which
deems that the Commonwealth’s natural resources (including wildlife) should be managed for the recreational
use of all citizens. As stewards of the state’s wildlife resource, PGC has grossly mismanaged wildlife for the
agency’s self-serving financial gain – again, a violation of the Pennsylvania Constitution.
The above-listed circumstances indicate a litany of mismanagement actions and violations of state law,
especially violations to Title 34 and The Pennsylvania Constitution. At the present time, PGC is a significant
deterrent to sound wildlife management, the future of sport hunting, and a vibrant multi-billion-dollar outdoor
industry in Pennsylvania. Serious thought should be given to passing HB 1483, or the cycle will be condemned
to continue.
Section 25. Conclusion and Recommendations. There are ten overriding conclusions that can be made from
the studies that have culminated in this report.
(1) PGC’s deer-reduction program was initiated by three men.
(2) It was not based on science or biological necessity, but, instead, on politics.
(3) For 18 years PGC has been operating under the influence of two special interests: (1) serving the wishes of a
forestry special interest as directed by DCNR and the private timber industry, and (2) serving the wishes of an
extreme environmentalist special interest as directed by DCNR and four environmental organizations. The goal
of the forestry special interest has traditionally been to eliminate deer and deer browsing in order to protect tree
seedling regeneration. A published quotation by a forestry company capsulized their goal; “Our target number
of deer is zero. However, we need to maintain enough deer to keep the interest of hunters who are needed to
kill them.” The goal of the environmentalist special interest has traditionally been to eliminate deer and deer
foraging on wildflowers, native shrubs, and other understory vegetation that represents habitat for nongame
wildlife such as songbirds.
(4) The three Chesapeake Farms students were hired by PGC to maintain the deer reduction program.
(5) The biological, social, and economic impacts resulting from PGC’s continuing deer-reduction program and
mismanagement of forest and wildlife resources are egregious, unacceptable, and unnecessary.
(6) There was no good reason for PGC to undertake the drastic and permanent reduction of the State’s deer
herd. It was an error – the greatest conservation mistake in the over-one-hundred-year-history of the Game
Commission.
(7) The above circumstances occurred because PGC understood that there was not adequate oversight of the
agency; that the Board of Game Commissioners and Legislature lacked the scientific expertise to recognize
infractions and hold them accountable; and that they were able to achieve any desired goal by baffling the
Board of Commissioners, Legislators, and sportsmen. Such action by PGC is unacceptable in that Legislators
have trusted in the honorable execution of the agency’s legislated mission, and in the ability of the Board of
Commissioners to assure that the agency is held to its Title 34 mission and Constitutional responsibility.
(8) PGC is withholding cutting adequate amounts of timber as necessary critical wildlife habitat with dramatic
impacts to deer, grouse, and an estimated 150 other species of game and nongame species in order to not
increase PGC revenue from the sale of harvested timber and to leverage a license-fee increase from the
Legislature.
(9) PGC is in gross and deliberate violation of at least two state laws: Title 34, Section 322(c)(13): The Game
and Wildlife Code; and The Pennsylvania Constitution.
(10) As was emphatically stated in a 2016 House Game and Fisheries Committee hearing by the agency’s
current executive director, the agency will not change its deer-management policy.
Therefore, the following actions are recommended.
(1) Those responsible for the deer-reduction program and resulting impacts should be held accountable.
(2) The agency, itself, should not be directly punished. PGC is a vital conservation agency that has strayed far
off its legislatively-directed path. Provisions should be set in place to hire staff who are not ideologues, but are
professionally trained wildlife biologists and leaders who understand the value of deer, wildlife resources, and
sport hunting as per the agency’s Title 34 mission.
(3) A new provision is needed to increase legislative oversight of the PGC and to provide the Legislature with
independent, unbiased, professional scientific advisory services toward holding the PGC accountable going
forward, and to assure that such a circumstance as has occurred over the past 18 years never happens again.
(4) The agency should not be merged with the Fish and Boat Commission, and should never be merged into
DCNR, whose politically motivated anti-deer attitude will likely take years to ameliorate.
(5) PGC should not be granted a license-fee increase by the Legislature. The agency’s egregious actions of the
past 18 years cannot be rewarded. Instead, the agency should satisfy its financial deficit by annually cutting
adequate amounts of timber as critically needed habitat for wildlife.
(6) HB 1483 was designed to resolve the biological, social, and economic problems that have been caused by
the Commission, to assure the creation of critical early stage wildlife habitat, and to provide the Legislature
with a permanent forest and wildlife advisory service toward holding PGC accountable going forward. Toward
this end, the bill should be passed immediately. It is the greatest answer toward resolving PGC’s crisis. When
passed and implemented, HB 1483 will function in the best interest of deer, grouse, and wildlife resources; the
health of the forest ecosystem; sportsmen and the future integrity of hunting; the economic well-being of the
outdoor industry, rural communities, and family businesses that rely on deer and abundant wildlife; thousands
of owners of family cabins and hunting camps; millions of Pennsylvania’s citizens and outdoor enthusiasts who
rely on abundant wildlife and healthy forests; the Pennsylvania Joint Legislature which is charged with the
responsible oversight of the Game Commission and adherence to the Pennsylvania Constitution; and the Game
Commission, itself. The bill will assure the return of upwards of 300,000 hunters who represent the first-line of
defense in protection of the Second Amendment. The details and benefits of HB 1483 are described in an
associated Part II report.
Finally, it should be noted.
Without legislative reform as per HB 1483, the above egregious biological, social, and economic impacts will
continue annually at the rate of over a billion dollars lost to the state’s economy and nearly $100 million lost in
tax revenues per year due to PGC’s mismanagement of deer, wildlife resources, and habitat. HB 1483 will
resolve this crisis. Those private and public individuals who support PGC’s deer-management policies and
oppose legislative resolution might be considered to be facilitating these losses each year. Failure to pass HB
1483 during this legislative session will, therefore, result in another year’s impacts to the Commonwealth
economy, sportsmen and the outdoor industry, rural communities, tax revenue collections, and millions of the
state’s outdoor enthusiasts.
Those few people and organizations who are primarily responsible for the deer-reduction program are listed in
the appendix along with a biographical sketch of the author of this report, John Eveland. (See Appendix H.)
Appendix A
DCNR’s Green Certification Program, the Cause of Deer Reduction (Documentation for Section 3)
On January 30, 2011 during a 3-hour meeting at the Game Commission’s Harrisburg headquarters between
John Eveland and the PGC (Executive Director Carl Roe and PGC’s Board of Commissioners), Commissioner
David Putnam stated to all in attendance:
• “There is no such thing as Green Certification that’s affecting the Game Commission and deer management.”
• “Nobody else has ever written about it. It’s never appeared in any newspaper articles.”
• “Green Certification only exists in John’s imagination. It makes for a good story.”
• “He has no documentation.”
That being said, consider the following.
A1. The Green Certification Program was a scheme to generate money for DCNR and an international
environmental organization. DCNR and PGC adapted it to permanently reduce the state’s deer herd.
A2. The German-based Forest Stewardship Council designed the Green Certification program.
A3. A newspaper account described how DCNR’s enrollment was a pilot program for the nation.
A4. DCNR contracts for pilot green certification review (1996-98).
A5. Other states invited to DCNR meeting reject green certification program based on lack of science.
A6. In 1998, DCNR enrolls in the program and “buys” its first green certification “award”.
A7. Bryon Shissler was the certifier’s representative, and James Grace and Daniel Devlin represented DCNR.
A8. Shissler and DCNR arbitrarily insert deer reduction into the contract in order to reduce the deer herd.
A9. Shissler and DCNR insert a goal to change deer management from traditional “game management” (which
favored sportsmen and hunting in accordance to Title 34) to a new “ecosystem management” philosophy (which
favored songbirds, oak and cherry regeneration, native shrubs, and wildflowers).
A10. DCNR claimed that their Green Certification award depended on PGC reducing the deer herd. This was a
scam, in that DCNR annually purchases the award. Deer reduction was a hoped-for bye-product of the deal.
A11. DCNR acknowledged that the concurrent buck/doe season was a method to reduce the deer herd, and that
antler restrictions were intended to frustrate hunters to turn their attention on killing more does.
A12. Outdoor writer Dave Drakula described the Green-Certification/deer-reduction scam in a 2001 newspaper.
A13. In a 2002 article, Game Commissioner John Riley berates the program as being against PGC’s mission.
A14. In 2012, the Pennsylvania Legislative Budget and Finance Committee (LB&FC) released a report on “The
Costs and Benefits of FSC Certification of DCNR Forests”.
A15. According to the LB&FC, FSC Certification is based more on politics than science.
Note: In 2000, PGC complied with DCNR’s Green Certification provision by killing 2,500,000 deer from 2000
to 2004, and has continued to comply with DCNR’s annual deer-reduction request from 2005 to the present.
THE FALACY OF GREEN CERTIFICATION
Green Certification is a scam that was concocted in 1993 by the Forest Stewardship Council (FSC) of
Bonn, Germany to promote forest stewardship. By 1995, FSC had certified the California group Scientific Certification Systems (SCS) to represent FSC's interests in America, and Bryon Shissler was
authorized as their Central Appalachian Regional auditor. Shissler's responsibility was to sell the
Green Certification program to state agencies and private landowners throughout the East, to then
determine what forest management criteria was to be used in granting Green Certification on an annual
basis, and then to serve as the auditor in determining whether the enrollee in the program was continuing to manage his land each year adequately enough to maintain the Green Certification label.
It is believed that DCNR was the first agency in America to enroll in the process. Shissler arbitrarily
selected deer reduction as the criterion on which to gauge DCNR's forest management success – if
DCNR were able to continue to yearly reduce the deer herd on State Forest Lands, Shissler's audit would recommend that DCNR be recertified, and SCS in California would then rubber-stamp DCNR's
new Green Certification label. This process permitted Shissler to dictate forest management/deer
reduction conditions to DCNR. Gary Alt made the comment that by enrolling in Green Certification,
DCNR had "a gun to its head".
Following are examples indicating that the Green Certification program is simply a money-making and
agenda-driven scheme.
• At a Harrisburg workshop in 1996, other states refused to participate in the program because they
said it was "value laden and not based on forest science."
• In 1996, Proctor and Gamble (a large timber grower in Pennsylvania) recognized that Green
Certification was a flawed process – that it was impossible to track certified versus non-certified logs
as they were being milled.
• Even if Green Certification were a legitimate program, it would take a full forest rotation of 80-100
years before any effects to the trees and resulting wood products (no matter how miniscule) could be
realized. There is, therefore, no difference between certified versus noncertified wood.
• In 2009, a family-owned lumber mill in Berks County became irritated by a Green Certifier's proposal for them to enroll in the program. The certifier identified himself as not being an
ENVIRONMENTALIST, but an ENVIRONMENTAL OPPORTUNIST. He offered to provide the
mill a Green Certification label for about $6,000 per year. They needed to do nothing to achieve
Green Certification except to purchase it. The husband-and-wife sawmill owners said that the
certifier asked them if they would consider making frames for corkboards to be sold to Lowe's, Home Depot, Target, and other retailers. The certifier told them that if they were certified, they
could state that the product was made from recycled material, but in reality, it was not.
• They were also told that once they were certified, if they didn't have certified wood they could
substitute other wood and still apply the Green Certified label.
The owners said that they refused to participate because it was too expensive, and because it was a
scam. Therefore, Green Certification is simply a revenue generator for environmental opportunists
which is purchased, not earned.
Appendix B
PGC Abandoned Title 34 for Audubon’s Ecosystem Management (Documentation for Section 6)
B1. Audubon designed a 364-page “ecosystem management” master document.
B2. Authors include Bryon Shissler (primary architect of the green-certification/deer-reduction program), Cindy
Dunn (Audubon Executive Director and soon to become DCNR employee), and Merlin Benner (of DCNR).
B3. The report described changing deer management to focus on biodiversity (songbirds, wildflowers, and
native shrubs. The process was to be achieved by eliminating deer to the extent possible.
B4. Audubon described its mission to restore natural ecosystems, focusing on birds, other wildlife, and their
habitats for the benefit of humanity and the Earth’s biological diversity.
B5. Audubon acknowledged Robert Boyd, Calvin DuBrock, Christopher Rosenberry, and Vernon Ross of the
Pennsylvania Game Commission for their assistance.
B6. Audubon’s major conclusion was to reduce deer in order to increase understory vegetation, to make DCNR
responsible for deer management on State Forests, and to merge PGC into DCNR – a more friendly player.
B7. Dan Devlin of DCNR organized a team to create DCNR’s official ecosystem management plan. Its authors
included Bryon Shissler (the primary architect of the green-certification/deer/reduction scheme), Christopher
Rosenberry (PGC’s deer management team leader), and Ben Jones (of the PGC).
B8. DCNR’s ecosystem management goal was to reduce deer to promote native plants and nongame animals.
B9. DCNR created a Conservation and Natural Resources Advisory Council to annually lobby PGC to continue
high annual allocations of antlerless deer allocations, to increase allocations each year, and to annually increase
DCNR’s allotment of DMAP permits. The DMAP program was designed to assist private land owners in
contending with specific high deer density situations, and was not intended for DCNR nor other public lands.
In 2000, PGC Rejected Title 34 and the PA Constitution and Adopted the Ecosystem Management Ideology
of DCNR and Audubon
The Game Commission's Deer-Management Program is in Direct Violation of Title 34 State Law, the
Pennsylvania Constitution, and the Federal Pittman-Robertson Act.
While DCNR's original Green Certification contract was being drafted from 1996-98 with the stipulation that a dramatic and lasting deer-reduction program was required in order to be Green Certified, DCNR created a
Conservation and Natural Resources Advisory Council (CNRAC) as a seemingly independent voice for DCNR.
In a March 27, 2002 letter to Mr. Vernon R. Ross, Executive Director, Pennsylvania Game Commission, CNRAC
(which was housed at a post office box in the Rachel Carson State Office Building by DCNR) wrote:
"Dear Mr. Ross:
The Conservation and Natural Resources Advisory Council (CNRAC) would like to take this opportunity to
express our support for the Pennsylvania Game Commission's continuing efforts to address deer management.
We are especially pleased to see the progress made as a result of the Commission's changes in management regimes (a.k.a. deer reduction) last year and encourage the Commission to continue to strengthen and solidify
this commitment again this year.
In 1998 all 2.1 million acres of the Pennsylvania State Forest system were provisionally certified by Scientific
Certification Systems (SCS) as being managed according to recognized standards of sustainability. This action made Pennsylvania's state forests the largest block of certified forest under single ownership in the nation and
possibly the world.
However, SCS certification of state forest land carries with it nine conditions, which the Bureau of Forestry is
striving to address. Should they determine at any point that satisfactory progress is not being made, certification could be jeopardized.
A principal condition still outstanding and for which the resolution is largely in the hands of the Commission is
Condition 2, which states: "Steady and continuous progress will be made by the Commonwealth of
Pennsylvania to develop and implement a deer management program that shifts from the current nutritional carrying capacity paradigm to one of diversity carrying capacity. This shift will view deer herbivory as a
natural process to be managed within the parameters of sustainable forest management, biodiversity
conservation, and forest economics."
Here the reader should note that this statement is technical jargon that was likely inserted into the contract by Bryon Shissler (considering that he had authored a very similar quotation in a published article) along with Dan
Devlin, and was intended to "mask to the laymen" the real intent of this statement. This Condition 2 signaled the
end of the traditional maximum-sustained-yield method of deer management that the Game Commission had so
effectively deployed for decades in making Pennsylvania one of the top two deer-hunting states in the nation, and
its replacement with a newly conceived ecosystem management method. In reality, it shifted PGC and DCNR wildlife management policies from game management to biodiversity management – nongame birds and
mammals, forest songbirds, and native shrubs and wildflowers. It changed the focus of the Game Commission
from serving the interests of sportsmen for recreational hunting, to serving nonconsumptive recreational interests,
forestry, and the forest ecosystem. It required dramatic and long-term deer reduction.
Continuing with CNRAC's letter to Vernon Ross, "…the problem is beyond the ability of the Bureau to resolve
on its own. The responsible management of Pennsylvania's wildlife is vested in the Game Commission, and it
must ultimately be this body which must implement the measures needed to management the Commonwealth's
deer herd to a level that will result in compliance with terms of the SCS certification. As you may know, Gary Alt
spoke to Council during its meeting in January and praised the fine cooperation that is occurring between the
Appendix C
DCNR’s Unspoken Reason for Deer Reduction: Old Growth Forests (Documentation for Section 7)
C1. In 2004, DCNR’s Chief Forester, Daniel Devlin, and three members of the Nature Conservancy published
an article in the Journal of Forestry describing DCNR’s “Old Growth Forest” program. As of 2002, the plan
had established 550,000 acres of old-growth forest to grow unaffected by human disturbance in perpetuity –
thus creating 300-500 year-old forests on about 26% of its State Forest land holdings. Additional buffers and
adjacent lands could increase the coverage to 32% of state forest stands. By the year 2140, the publication
indicated that the program would have been increased to include 47% to 55% of state forest stands.
C2. DCNR and the Nature Conservancy have established 25-50% of Pennsylvania’s State Forest lands to grow
in perpetuity -- unabated by timbering and human disturbance and without impacts by deer in order to recreate
Colonial-style forests. In the publication, DCNR and the Nature Conservancy stated:
• “The result is that Pennsylvania faces a decades- and even centuries-long gap before old-growth forest
functions return to the Commonwealth’s forest lands.”
• “Reducing Pennsylvania’s deer herd will likely require a long-term political process.”
• “This will not be easy.”
Note: According to DCNR’s publication, 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. Today’s socioeconomic impacts that are now estimated to be over $1 billion per year to family
businesses and rural communities with a concomitant loss of nearly $100 million per year in lost tax revenue
will increase to levels that are currently difficult to calculate or even imagine. Establishing and supporting such
a plan is both irresponsible and a violation of The Pennsylvania Constitution, in that today’s State population is
not that of Colonial Penn’s Woods, but, instead, 12.8 million citizens who enjoy hunting, camping, hiking,
photographing, and appreciating abundant wildlife on DCNR’s 2.5 million acres of State Forests. Today’s
society requires the “wise, multiple-use” conservation of the Commonwealth’s natural resources, which
includes abundant wildlife and health forests for human recreation and enjoyment, and responsible energy
development to meet the demands and job requirements of a healthy society. Preserving upwards of 50% of our
2.5-million-acre system of state forest lands with closed canopies blocking sunlight from reaching the forest
floor, and the resultant dark and barren forest floor devoid of regeneration and of even moderate densities of
wildlife, is impractical. While it is intriguing and of educational value to preserve some of these areas for future
generations, converting half of our public lands to such an endeavor is unacceptable.
The Pennsylvania Game Commission has been participating in DCNR’s long-term political plan to reduce deer
on state forests and old growth areas for nearly two decades – a violation of PGC’s legislative mission as
directed in Title 34, and in violation of The Pennsylvania Constitution.
Appendix D
By the Numbers: How PGC Decimated the Deer Herd (Documentation for Section 9)
D1. From 2000-04, PGC killed 2,500,000 deer from a stable 1999 population of about 1,500,000 deer.
D2. Based on a scientific analysis of deer population dynamics, over this 5-year intensive herd-reduction period,
PGC reduced the statewide deer herd by 60% from 1,500,000 to only around 600,000 deer. At that point from
2005 to the present, PGC continued to claim annual harvests averaging 330,000 to over 350,000 deer. If this
were accurate, then deer would have been completely exterminated from the state by the fall of 2008. In other
words, in order for PGC’s continuing excessively high annual harvest claims to be accurate, by 2018 PGC
would have needed to import 3,461,251 deer from other states and shot every one of them.
D3. Each year John Eveland responds to PGC’s excessively high harvest claims and demonstrates with a
scientific assessment the biological impossibility of the agency’s claim.
D4. For PGC’s 2017 claimed harvest to be accurate, there would need to be 84 deer per square mile on every
square mile of forest land in the state down to one acre in size, or 50 deer per square mile on every parcel of
land area in the Commonwealth, including backyards, ballfields, and the city streets of Pittsburgh and
Philadelphia.
Note: PGC has attempted to explain this absurd circumstance by stating that today’s low deer populations
across northern-tier counties are compensated by higher deer densities in southern counties. However, for this
claim to be accurate, there would need to be an average of 166 deer per square mile across southern counties.
PGC’s false harvest claims can only be explained by incompetence of deception.
OVERSHOOTING PENNSYLVANIA’S DEER HERD
Scientific Population-Dynamics Assessment Indicates that PGC Killed 60% of the Deer Herd
By John Eveland March 23, 2018
The following table is a scientific assessment of the actual hunting impacts that have occurred over the past 17
years to Pennsylvania’s deer population as a result of an over-zealous deer-reduction program by the Pennsylvania
Game Commission. As presented in the table, for nearly two decades spanning from the 1980s to 1999, the Commonwealth’s deer herd had remained at a relatively stable number of 1,500,000 animals with a sustained
annual harvest that averaged 378,000 deer. As a result, Pennsylvania was acknowledged as one of the top two
deer-hunting state’s in the nation during that period.
However, in 2000 the Commission, at the urging of DCNR and Audubon, initiated a five-year assault on the deer herd that would turn out to be the greatest conservation mistake in the over-one-hundred-year history of the
agency. From the fall of 2000 through 2004, the Commission killed an officially reported 2,382,353 deer – about
500,000 deer above the normal number that would have been harvested during these five years. It represented
about 100,000 extra pregnant does and fawns killed per year.
Based on the biological characteristics of deer reproduction and herd growth, after the 2004 hunting season and
by the spring of 2005, there would have remained only 604,710 deer in Pennsylvania, indicating that the
Commission had orchestrated the slaughter of 60% of the herd in five years. These numbers are not assumptions,
but were determined from actual population dynamics of white-tailed deer in Pennsylvania and other states.
Conversations with PGC Commissioners and staff around that time indicated that a uniform reduction had not occurred across the state, with the herd being reduced to a much greater extent in northern, eastern, and western
tiers, and with higher herd densities remaining in some southern counties. PGC stated in private conversations
that the herd had been way overshot in the north, leaving only 1-2 deer per square mile in some regions, and that
deer had been literally exterminated in some eastern regions.
At that point in the spring of 2005, the Commission stated that it was planning to stop the assault, and to maintain
the herd at this dramatically reduced number – 604,710 deer (although the agency staff would not indicate how
far the herd had been reduced to sportsmen, legislators, or even its own board of commissioners). To accomplish
this stabilization in herd size, the Commission could have only harvested 151,178 deer in 2005 and all subsequent
years. Harvesting fewer deer would have allowed the herd to grow in numbers, while harvesting more deer per year would result in the continuing decline of the herd. Nevertheless, in 2005 PGC continued to release an
excessively high number of antlerless allocations, and announced that they harvested 354,390 deer that year (see
the table). The next year they reported that the harvest was even higher at 361,560 deer, and the Commission has
continued to report harvest numbers of about 330,000-360,000 deer every successive year to the present.
According to basic herd biology, if the Commission’s harvest figures were correct, then the herd would have been
completely exterminated from the Commonwealth midway through the 2007 hunting season – zero deer in the
state. From 2008 to the present, the agency would have been killing an annually increasing deficit of deer that
would have reached minus 3,093,961 deer by the spring of 2017. Put another way, in order for the Game
Commission to be harvesting the number of deer that they annually report, the agency would have needed to import 3,461,251 deer from other states during 2008-18, and shot every last one of them.
If the Commission’s deer-reduction program and their absurd harvest claims were not so devastating to deer and
wildlife resources, to the tradition of sport hunting, and to the socioeconomic well-being of the Commonwealth,
this circumstance might seem laughable. Instead, it has become a conservation crisis that can only be explained by Game Commission incompetence or deception. The agency should be held accountable for what it has done.
Pennsylvania’s only means to resolve this crisis is to pass pending legislation – HB 1483.
DEER POPULATION DYNAMICS & PGC HARVEST CLAIMS
Explained Only by PGC Incompetence or Deception
I. Population at Equilibrium before Coyotes and Deer Reduction
End of Summer
Year Overwinter Base Population Harvest
1997 1,500,000 1,875,000 378,0001
1998 1,500,000 1,875,000 378,000
1999 1,500,000 1,875,000 378,000
_____________________________________________________________________________________________________________________________ _
II. Reduction Period Actual Harvest
2000 1,500,000 1,875,000 504,6002
2001 1,373,400 1,716,750 486,014
2002 1,230,736 1,538,420 517,529
2003 1,020,891 1,276,114 464,890
2004 811,224 1,014,030 409,320 _____________________________________________________________________________________________________________________________
III. PGC’s False Harvest Claims
2005 604,710 755,887 354,3903
2006 401,497 501,871 361,560
2007 140,311 175,389 323,070 4
2008 -147,681 0 335,850
2009 -483,531 0 308,920
2010 -792,451 0 316,240 2011 -1,108,691 0 336,200
2012 -1,448,891 0 3 43,110
2013 -1,788,001 0 352,920
2014 -2,140,921 0 303,973
2015 -2,444,894 0 315,813 2016 -2,760,707 0 333,254
2017 -3,093,961 0 367,159
2018 -3,461,2515 0 ?
_____________________________________________________________________________________________________________________________ _
Footnotes: 1. Average deer harvest from !980s through 1999. 2. PGC-acknowledged harvests. 3. PGC said they stabilized the herd in 2005 at a reduced population. Thereafter, the harvest would have to have been 151,178 per year in order to maintain a stable population. Instead, PGC claims about 350,000. 4. If PGC were killing the average number of per year as they claim, extinction would have occurred in late 2007. 5. To achieve PGC’s harvest claims from 2007-2017, they would have needed to import 3,461,215 deer into PA from other states and shot them all. Note: If there were no coyotes and bears in Pennsylvania, PGC would need 1.5 M deer to harvest 367,159. In reality, however, with predation it would require over 2.3 M deer at estimated fawn predation, representing 84 dpsm on every square mile of forestlands, or 50 dpsm on every square mile of land area in the state, including the city streets of Pittsburgh and Philadelphia.
John Eveland • Independent Forester, Wildlife Biologist, and Ecologist • March 23, 2018
AN INDEPENDENT, SCIENTIFIC ASSESSMENT
OF THE PENNSYLVANIA GAME COMMISSION'S
ESTIMATED 2017-18 DEER HARVEST
By John Eveland
March 23, 2018
Abstract. This report represents the eighth in a series of independent, scientific assessments of PGC's annual
deer harvest estimates. PGC has estimated that 367,159 deer were harvested in Pennsylvania during the 2017-18
hunting season, representing a 10% increase over PGC’s previous year’s estimated harvest, which, itself, had
been claimed to be a 6% increase over the previous year’s harvest (2015-16). However, the author has calculated
that in order for this number to be accurate, from a biological perspective there would need to be 1.8-2.3 million deer in the state. From a geographical perspective, this number would represent 68-84 deer per square mile
(dpsm) on every square mile of forestland in the state up to one acre in size, or 41-50 dpsm on every square mile
of Pennsylvania land area including the city streets of Pittsburgh and Philadelphia. Further, from social and
economic perspectives, considering that many woodlands during the fall deer season are devoid of orange coats
and gun shots because of the lack of deer, that hunting camps and family cabins stand empty and for sale across the northern tier because of the lack of deer, that bankruptcies and lost family businesses proliferate in Potter and
Cameron Counties and throughout other northern-tier counties because of the lack of deer, and that official
Pennsylvania Legislative Budget and Finance Committee investigations (2012/2017) reported that as of 2012
PGC's deer-reduction program was costing the Commonwealth $501.6 million per year in lost economic activity
and $40 million per year in lost tax revenue (economic impacts that by 2017 had increased to $1.16 billion per year in losses to rural communities and the Commonwealth and $92.5 million in annual lost tax revenues), then
even without the scientific evidence within this document, common sense dictates that the agency cannot be
harvesting today nearly the same number of deer per year as were harvested during the heydays of deer hunting
from the 1960s through the '90s – not even close. From 1986-1999, the average harvest was 379,137 deer for a
statewide herd that was biologically determined to number approximately 1,500,000. Therefore, as had been the case for the assessments of PGC’s previous harvest claims, it is again concluded that PGC's erroneous harvest
claims can only be explained by incompetence or deception. This circumstance clearly exemplifies the need for
change and accountability regarding PGC's deer management program.
It should be noted that PGC’s Board of Commissioners had approved a 7.5% increase in antlerless license allocations for the 2017 season – a 56,000 increase in doe tags from 748,000 in 2016 to 804,000 for 2017. PGC’s
deer team had requested 873,000—an increase of 125,000 doe allocations over the previous year, indicating that
the Commission has no intention of returning our State Mammal to Penn’s Woods.
I. INTRODUCTION
For the past seven years (2010-17), the author has scientifically assessed the Pennsylvania Game Commission's
annual deer harvest estimates in order to determine their validity. This document provides an independent,
scientific assessment of PGC's 2017-18 estimated deer harvest, and is intended to provide legislative decision makers and sportsmen with sound scientific information toward making wise deer management decisions.
Appendix E
PGC Hired Three Chesapeake Farms Students to Reduce PA’s Deer Herd (Documentation for Section 12)
E1. PGC’s Game Commissioners asked John Eveland to investigate a claim that all three of the agency’s deer
biologists came from the same university. All three graduated from North Carolina State University under the
same mentors, and conducted their graduate research on a small, 5-square-mile agricultural demonstration area
on the Eastern Shore of Maryland called Chesapeake Farms. From their graduate theses, all three were trained
to eliminate impacts to agricultural crops that are caused by deer. They were not trained as conventional
wildlife biologists from other universities to view deer as a valuable natural resource.
E2. North Carolina State proudly announced in a university newsletter that all three of Pennsylvania’s deer
biologists were from NC State.
E3. Two views of Chesapeake Farms show where PGC’s 3-member deer team was trained.
E4. As an example of the deer-team’s contempt for sportsmen, a member of the team, Jeannine Fleegle, wrote a
Game News article in which she castigated sportsmen and concluded:
• “So the Commission once again said no to demands calling for more deer as it stood in the midst of countless
blue balls.”
E5. In another article by the deer team, Jeannine Fleegle stated:
• “The hate and loathing I experience this time of year has nothing to do with hunting. I recently shared a
photo of a happy pile of deer heads on our Twitter feed.”
• “There is nothing bad about a pile of deer heads. Why?...one less deer on the landscape.”
• “I am a non-hunter! Other than the smell and occasional bulging eyeball, I have never been offended by a
deer head.”
• “If you like trees and flowers and birds, then be thankful for that pile of deer heads.”
Note: In the words of Ms. Fleegle and the deer team, when will the Pennsylvania General Assembly say
“Enough Is Enough” to PGC and its deer program?
Sent: Friday, October 28, 2011 9:42 AM
Subject: PGC's Chesapeake Farms Connection
Commissioners,
Based on rumors circulating within the Pennsylvania Game Commission, I have investigated and
uncovered a circumstance of great concern to sportsmen and those within the Commission who still believe in the original intent and chartered mission of the agency as described under Title 34
-- The Game and Wildlife Code. These findings leave no doubt that the deer reduction program
was an orchestrated event that was intended to advance a special-interest agenda -- an agenda
that is not in the interest of sportsmen nor recreational hunting -- and that all three deer biologists
on the staff were hand-picked to advance this agenda. There is also no doubt that these staff members, those who hired and supervise them, and those within the agency who continue to
facilitate this anti-deer, anti-sportsmen, and anti-recreational hunting agenda are in direct
violation of State Law -- Title 34, Section 322(c)(13).
I leave it to the readers of this document, PGC's Chesapeake Farms Connection, to decide for themselves how this circumstance unfolded and how it should be addressed. Nevertheless, it is
needless to say that much is askew, and there is much for which to be concerned, within the
confines of the Pennsylvania Game Commission.
John Eveland
Sent: Friday, October 28, 2011 11:03 AM
Subject: Re: PGC's Chesapeake Farms Connection
Dear John:
Appreciate the time that you are spending on this matter and the information that you are
providing to Commissioners.
As a long time critic, I think it should now be obvious to even the casual observer that our deer
management plan for the past eleven (11) years has not been based on science, but on a political
agenda that has had, and is continuing to have, disastrous consequences for our century-old
hunting tradition in this state.
I believe the question is now, will a majority of the PGC Board allow this policy to continue, or
will it take corrective action?
Tom Boop PGC Commissioner
CHESAPEAKE FARMS
A 3,300 acre DuPont agricultural demonstration area on the Eastern Shore of Maryland.
Appendix F
Impacts from PGC’s Deer Program: Worst Hunting State in the Nation (Documentation for Sections 15, 16, and 18)
F1. A national 2017 Deer Summit concluded that losing deer would mean a financial disaster for a state.
F2. A national publication ranked Pennsylvania as the worst deer hunting state in the nation.
F3. A sad and frustrated sportsman’s letter berating PGC’s deer management program serves as a microcosm
for hundreds-of-thousands of Pennsylvania hunters.
F4. This is a listing of the egregious biological, social, and economic impacts that are being caused by PGC’s
mismanagement of deer, wildlife resources, and habitat.
F5. An 8-foot banner depicts the over 150 wildlife species that are either currently in decline or at imminent risk
because of PGC’s failed policies.
F6. From a 2011 study, the Pennsylvania Legislative Budget and Finance Committee determined the economic
impacts of deer reduction and the loss of hunters from 2001 to 2010. The LB&FC assisted in further
determining these socioeconomic impacts from 2001 to 2016.
F7. During a 2016 meeting in the chairman’s office of the House Game and Fisheries Committee, PGC’s
executive director stated that the agency’s deer management program was second to none in the country, that
most sportsmen loved the agency’s deer program, and PGC would not change it (even if a bill were passed
directing it). As a result, John Eveland was asked by select legislators if he would verify PGC’s claim that most
sportsmen love the agency’s deer program. Eveland complied with a survey and report to the Legislature.
F8. The report indicated that 109 out of the survey’s 110 sportsmen’s organizations, outdoor-related businesses,
and chambers of commerce rejected PGC’s deer management program and requested legislative reform. PGC’s
habit of false claims is indication the need for increased legislative oversight and reform of the agency.
F9. An assessment by Jack Krafft, owner of First Fork Lodge and former President of the Potter County Visitors
Association, represents the socioeconomic impacts to thousands of family businesses that have been caused by
the Game Commission’s mismanagement of Pennsylvania’s State Mammal.
WIDEOPENSPACES (A National Publication)
8 Worst States to Bowhunt This Fall (Even
with a Crossbow)
Posted by Brad Smith
August 10, 2016
If you live in one of the worst states to
bowhunt, you might want to think about an out
of state lease.
First off, I’m sorry for the crossbow jab. Truth be told, you could probably hunt with a hand
grenade and still strike out in one of these below states. Of course, nothing beats time in the
stand, but if you are hunting in one of the worst states to bowhunt, odds just are not on your side.
A lot of states are doing things right when it comes to deer and deer hunting. However, a
few states are on a stark downward trend. So let’s get down to it. Sharpen your knives, craft
your witty social media jabs, and get ready to get angry.
Fortunately, the QDMA put out a lot of stats to back up what you are going to read and the
trending numbers don’t lie. Deer declines are a real thing in a lot of places for a variety of reasons. The trends also speak loud and clear as well. With that in mind, just look below to see
what we predict will be the worst states to bow hunt in 2016, not just by the trends, but mostly
our gut.
Pennsylvania
Good old Penn is the unanimous winner as the worst state to not only bowhunt, but just
really hunt in general. With the highest population of hunters in the country, averaging about
20 per square mile, finding a place just to bowhunt can be a challenge. On top of that, there are a
lot of political motivations at play too with more hunting rules than most states. Public land can
be a madhouse and private land is only getting more and more expensive. To make matters
worse, CWD is only spreading.
IMPACTS FROM PGC’S DEER, WILDLIFE, & HABITAT FAILURES
PGC failures are costing the state $1.2 billion in lost economic activity and $92 million in tax revenue.
In 1998, PGC changed its wildlife management policy to comply with the forestry and environmental special
interests of DCNR. This new DCNR/PGC “ecosystem management” philosophy is focused on preserving old-
growth forests, native shrubs, and wildflowers at the expense of the deer herd, grouse, wildlife habitat, sport
hunting, 150 other species of wildlife, the multi-billion-dollar outdoor industry, and millions of the state’s citizens .
The magnitude of the biological, social, and economic impacts has been egregious and unacceptable. PGC’s
mismanagement of deer, wildlife, and forest resources is causing the following negative impacts:
1. Collapsed Deer Herd. PGC caused the near-biological collapse of the statewide deer herd. During a 5-year period from 2000-2004, PGC killed 2,500,000 deer – reducing the herd from a healthy 1,500,000 deer by 60% to
only 600,000 animals. According to Commissioners, in some regions the herd was overshot to an unhuntable
number, leaving only 1-2 deer per square mile. From 2005 to the present, PGC has attempted to stabilize the herd
at these permanently reduced numbers using high annual allocations of antlerless licenses and DMAP permits.
2. Critical Habitat Loss. Wildlife habitat over the combined nearly 6,000-square-mile system of public game
and forest lands is deteriorating at an unprecedented rate, with no intension to create new critical habitat.
3. Declining Wildlife. Over 150 species of wildlife are in rapid decline or in imminent danger because of poor
and declining habitat. Grouse are at a 50-year low with no end in sight. Bat populations are nearing extinction.
4. Empty Cabins. Family cabins and hunting camps stand empty due to the lack of deer and other wildlife.
5. Declining Sportsmen. According to the Legislative Budget and Finance Committee (LB&FC), as of 2010
117,000 sportsmen had quit hunting. As of 2016, a total of 270,000 hunters had been effectively lost as hunters and economic generators due to the lack of deer and failed hunting regulations.
6. Economic Disaster. According to the LB&FC, as of 2010 the impact in lost Commonwealth economic activity
was calculated to be $501.6 million per year. The Cameron County Chamber of Commerce referred to PGC’s
deer program as “economic suicide for the county. Most family businesses that have not closed are down 50-60%.” The loss of jobs is estimated at over 13,000, especially in rural communities. As of 2016, the economic
impact to the Commonwealth had increased to $1.16 billion per year, with a cumulative impact of $10 billion.
7. Lost Tax Revenue. According to the LB&FC, as of 2010 the impact in lost tax revenue was $40 million per
year. As of 2016, lost tax revenue had increased to $92.5 million per year.
8. PGC Budget Deficit. PGC is calculated to be losing $8.1 million per year in lost hunting-license fees. Note
that PGC is requesting a license-fee increase of $8M. Considering that PGC’s deer program has caused a lack of
deer with resulting loss of hunters, PGC has caused its own budget deficit.
9. Causing CWD. PGC’s failed CWD policy is increasing the spread of the disease and threatens to destroy deer
and elk herds.
10. Zero Trust. PGC has destroyed its trustworthy relationship with sportsmen, legislators, and citizens.
HB 1483 is designed to correct the greatest conservation mistake in the history of the Game Commission.
Prepared for the Governor and Pennsylvania General Assembly by John Eveland • January 26, 2018
Economic Impact of PGC’s Deer Management Program
Four economic impact analyses were made based on two financial assessments of the Game
Commission’s deer-management program by the Pennsylvania Legislative Budget and Finance
Committee. LB&FC conducted the financial assessments in 2012 and 2017, and they depict the
economic impacts that existed in 2010 and 2016.
A. Loss of hunters because of PGC’s deer-reduction program and the lack of deer:
1. As of 2010, 117,000 hunters had quit.
2. From 2010 to 2016, hunters on the first day of deer season declined by 200,000. About 150,000 of this number still bought a license but did not hunt, with the other 50,000 buying archery licenses. As of
2016, a total of 270,000 hunters were effectively lost as hunters and economic generators.
B. Annual economic impact to the Commonwealth, especially to rural communities:
1. As of 2010, there was $501.6 million in lost economic activity per year.
Note that the Cameron County Chamber of Commerce referred to PGC’s deer program as “economic suicide for
the county. Most family businesses that have not gone bankrupt or closed are down 50-60%.” This is a microcosm of the economic impacts across the Northern Tier. Family cabins and hunting camps stand empty
due to the lack of deer and other wildlife.
2. As of 2016, the economic impact to the Commonwealth had increased to $1.16 billion per year.
C. Annual lost tax revenue to state and local governments due to PGC’s deer program:
1. As of 2010, $40 million of tax revenue was lost per year.
a. $25 million in annual lost state government tax revenue.
b. $15 million in annual lost local government tax revenue.
2. As of 2016, lost tax revenue had increased to $92.5 million per year.
a. $57.8 million in annual lost state government tax revenue.
b. $34.7 million in annual lost local government tax revenue.
D. PGC is calculated to be losing $8.1 million per year in lost hunting-license fees.
Note that PGC is requesting a license-fee increase of $8M. PGC’s deer program caused a lack of deer with resulting loss of hunters. Consequently, PGC has caused its own budget deficit.
Prepared for the Pennsylvania General Assembly by John Eveland • September 13, 2017
A MICROCOSM OF
BUSINESSES AND ORGANIZATIONS THAT SUPPORT
REFORMING THE GAME COMMISSION'S
DEER-MANAGEMENT PROGRAM
Findings are Based on a 72-Hour Survey of Pennsylvania Sportsmen's Organizations and
Businesses that are Affiliated with the Outdoor Industry
April 2016
A Bipartisan Request by the Pennsylvania Legislature
Conducted by John Eveland
With Assistance from
Phil Wagner, Nelson Haas, Jack Krafft, Randy Santucci,
Pete Kingsley, Wayne Haas, and Blaine Toy.
Introduction and Summary
In January 2016, a House Game and Fisheries Committee hearing was held regarding pending deer
management legislation. At that time, three attending Game Commission representatives stated:
• that the Commission's deer-management program was second to none in the country; • that a majority of hunters are in approval of the program; and
• that the Commission would be making no significant changes to the program.
Therefore, in an effort to determine the validity of the Commission's claim "that a majority of hunters are
in approval of the agency's deer-management program", a 72-hour telephone survey was conducted in mid-April 2016. Those who were surveyed were asked if they approved of the Commission's current deer-
management program, or if they were in favor of deer-management reform.
The survey included 110 sportsmen clubs and businesses from the central and northern portions of the
state. A sampling of five county chambers of commerce representing roughly 2,000 businesses were only listed as five (5) contacts on the survey. No individual sportsmen were called, only sportsmen clubs with
most ranging from about 1,000 to 10,000 members. Some were much larger. Of the 110 contacts, 109
were in favor of deer management reform, and only 1 call resulted in favor of PGC (and even that was due
to a political connection). This represents only a small microcosm of the many thousands of businesses and
many hundreds of thousands of sportsmen who want dramatic deer management reform. The survey counted about 700,000 sportsmen who want reform. Their comments were compiled, and the animosity
for the Game Commission cannot fully be described, in that many of the comments by club presidents and
business owners were so laden with expletives that they were omitted from this report. It is a demonstration
of the overwhelming degree of dissatisfaction with the Commission's deer-management program, and the
desire for dramatic legislative reform.
Of the sportsmen clubs and outdoor-industry related businesses that were surveyed, 96% of the
sportsmen associations, 99.8% of the members (as represented by the total membership of the
associations), and 100% of the businesses were opposed to the Game Commission's deer-management
program and were, instead, in favor of legislative deer-management reform.
Results of the Survey
A. Coalition of Pennsylvania Sportsmen. A baseline coalition of sportsmen, firearms owners, and state
camp owners comprised of five organizations and representing about 600,000 members has spear-headed
efforts to reform the current deer-management program through passage of new deer management legislation. This Coalition of Pennsylvania Sportsmen (COPS) consists of:
1. Allegheny County Sportsmen's League (ACSL), serving as the voice of 200,000 sportsmen.
2. Unified Sportsmen of Pennsylvania (USP), representing 70,000-100,000 members.
3. Eastern Pennsylvania Firearms Coalition (EPFC), representing 150,000-175,000 members.
4. Firearm Owners Against Crime (FOAC) representing 28,000 members and 76,000 associates.
5. Pennsylvania State Camp Association (PSCA), representing 5,000 state-leased camps and
over 60,000 members.
These organizations are depicted in the following table, and their individual letters of support of deer
management reform - a pending deer management and accountability bill - are available upon request.
Deer Reduction Impact to Potter County Businesses
A Microcosm of Impacts that continue throughout Pennsylvania's Outdoor Industry
From personal conversation between John Eveland and Potter County businessman, Jack Krafft,
on Sept. 1, 2013:
• Currently, 145-150 businesses belong to the Potter County Visitors Association.
• Over 60 of these businesses are now for sale because of deer reduction.
• This does not count the small businesses that do not belong to the PCVA that have already
closed or are now for sale.
Jack Krafft First Fork Lodge
1104 Costello Road
Austin, PA 16720
(814) 647-8644
These socioeconomic costs are exemplified in northern-tier counties. According to Jack Krafft,
owner of First Fork Lodge in Potter County, "On Eleven Mile Run Road I counted only 9
vehicles in 11 miles on the first day of the 2004 deer season, and on the first Saturday only 1
vehicle in 11 miles. Traditionally the lodge has had the same 27 out-of-state hunters on the first week of rifle buck season. Combined, the 27 hunters saw only 10 deer during the week. Only 2
returned for 2005, representing a loss of $60,000 for the lodge." Jack lost 55 of 57 out-of-state
bow hunters because of the lack of deer. They said that they would hunt in Wisconsin or
Michigan in the future. There were nine motels for sale between Galeton and Coudersport.
In a May 8, 2015 Pennsylvania Outdoor News article entitled "New England visit offers
perspective", Editor Jeff Mulhollem wrote, "The small towns in New England that I saw were more vibrant than those in Pennsylvania, particularly in our Northern Tier. The New England
small towns have hundreds and hundreds of small businesses. Reminded me of towns in our
state's northcentral region decades ago when I was young. Pennsylvania small businesses that
cater to hunters have disappeared with the reduction of the deer herds, and fisherman and
sightseers don't spend much money – even in the elk range."
Appendix G
PGC’s Destruction of Deer and Hunting: Hunter Loss by the Numbers (Documentation for Sections 19 and 20)
G1. According to the Pennsylvania Legislative Budget and Finance Committee, from 2001-11 the number of
Pennsylvania hunters declined from 1,050,000 to 933,000 while hunting participation nationally rose by 5%.
G2. The American Sportfishing Association compiles hunting and fishing data under a grant from the U.S. Fish
and Wildlife Service.
G3. This National Survey of Fishing, Hunting, and Wildlife-Associated Recreation is conducted every 5 years.
From 2006 to 2011, hunting participation rose, with the report stating: “In short, both databases show a recent
slight trend in the number of hunters, albeit not to the peak levels in the 1980s.”
G4. As depicted from the national survey in this table, while hunting participation rose from 2006 to 2011,
hunting participation declined in Pennsylvania by 25% from 933,000 to 699,000 hunters. The national survey
ranked Pennsylvania 45th
out of the 50 states in hunter retention from 2006 to 2011.
G5. A PGC news release and associated newspaper articles indicated that from 2010 to 2016 PGC had lost an
additional 200,000 hunters. According to the PGC, hunters during the first day of the rifle deer season declined
from 750,000 to 550,000. PGC claimed that these 200,000 hunters who were no longer participating in rifle
deer season had become archery hunters. However, a review of the number of archery hunters from 2010 until
2016 (the time period in which crossbow hunting had been legalized by the PGC) resulted in a gain of only
about 50,000 hunters – leaving a decline of 150,000 hunters as unaccounted.
Note: It is likely that in addition to the decline of upwards of 300,000 hunters in Pennsylvania and possibly
more from 2001 to 2016, many more hunters may be purchasing licenses annually out of tradition and failing to
go afield to hunt due to the lack of deer. Such hunters would not be purchasing outdoor related goods and
services and thus would not be contributing to the hunting-related economy. The hunter-participation numbers
as presented in this Appendix G indicate that the economic impacts associated with the loss of deer hunters
could be much higher than those that have been previously calculated by the LB&FC and listed in this report.
Appendix H
Those Responsible for Deer Reduction / About the Author (Documentation for Section 25)
H1. Those responsible for the deer-reduction program are listed and ranked in order of significance.
H2. The author’s capabilities and experience are presented in a brief biography.
H3. After over a decade of investigating the efficacy of the deer-reduction program at the request of a former
governor, members of the State House and Senate, and Game Commissioners, themselves, John Eveland
concludes this report with a personal note.
Those Responsible for Deer Reduction and Resulting Effects
Following are the principal individuals who designed, initiated, and have maintained the Pennsylvania Game Commission’s deer-reduction program. They are listed in their perceived order of significance.
Primary Architects
1. Bryon P. Shissler. Representative for the German-based Forest Stewardship Council (FSC) at the time
of the DCNR/FSC Green Certification Award agreement in 1998. Independent wildlife biologist operating a deer-culling business within PA parks and municipalities.
Consultant to DCNR. Working associate with Audubon PA and co-designer of Audubon’s
and DCNR’s ecosystem-management/deer-reduction master plans.
2. Dan Devlin. DCNR’s Chief Forester.
3. Calvin W. DuBrock. Former PGC Chief of Wildlife Research and Management.
Facilitators
4. Gary Alt. Former PGC deer-management leader.
5. Cindy Adams Dunn. Former President of Audubon PA during inception of the deer-
reduction program. Currently Secretary of DCNR. 6. Timothy D. Schaeffer. Former President of Audubon PA succeeding Cindy Dunn. Now a
high-ranking employee of the Pennsylvania Fish and Boat Commission who some believe
is a primary candidate to assume leadership of the agency, or of the combined PGC/PFBC
if the agencies are merged.
7. James Grace. DCNR 8. Christopher S. Rosenberry. PGC 3-member Deer Team Leader.
9. Bret Wallingford. PGC 3-member deer team biologist.
10. Jeannine Fleegle. PGC 3-member deer team biologist.
11. Vernon Ross. Former PGC Executive Director.
12. Carl Roe. Former PGC Executive Director. 13. Merlin Benner. Former DCNR wildlife biologist.
14. Michael DiBerardinis. Former Secretary of DCNR.
15. Scot Williamson. Vice President of the Wildlife Management Institute.
16. Ben Moyer. Outdoor writer.
17. David Levdansky. Former member PA House of Representatives 18. Roger Earl Latham. Principal author of Audubon’s 362-page ecosystem-management/
deer-reduction master plan and DCNR’s 49-page ecosystem-management/deer-reduction plan.
19. Robert Boyd. PGC executive.
20. Susan L. Stout. U.S. Forest Service. Worked closely with Audubon, DCNR, and PGC regarding
implementation of deer-reduction program and PGC’s change-of-policy from game management to ecosystem management (favoring nongame wildlife, native shrubs, and wildflowers).
Agencies and Organizations (listed in perceived order of significance)
1. PA Department of Conservation and Natural Resources (DCNR)
• DCNR’s Conservation and Natural Resources Advisory Council 2. Pennsylvania Game Commission (PGC)
3. Forest Stewardship Council (FSC)
4. Audubon Pennsylvania
5. International Rainforest Alliance
6. The Nature Conservancy 7. Private Pennsylvania timber companies (two lobbyists)
ABOUT JOHN EVELAND Forester, Wildlife Biologist, and Ecologist
Areas of Special Scientific Expertise: Big Game Management, Biodiversity and Ecosystem
Management, Wildlife and Forest Ecology, Earth Systems and Environmental Quality,
Endangered Species, and Energy/Environment Relationships
John Eveland is by education and profession a forester, wildlife biologist, and ecologist. Of the three big game
mammals in Pennsylvania (white-tailed deer, black bear, and elk), he conducted the original statewide
research, wrote the original state management plans, and was directly involved in the successful recovery of two of these species -- black bears and elk. From his Penn State research, his management recommendations
and first population estimate of only 1600 bears in the Commonwealth were instrumental in closing
Pennsylvania's bear season in multiple years during the 1970s and in changing from a one-week to a three-day
season. As a scientist on the Penn State faculty, he conducted the first ecological research and population
assessment of Pennsylvania's elk herd, discovered the brainworm disease in the elk herd, recommended the elk-hunting lottery system, and designed the original plan for PA Wilds and the Elk Country Visitor Center.
Eveland left the Penn State faculty to accept a position with Westinghouse Electric Corporation in Pittsburgh.
There, John conducted environmental field studies and selected the sites for some of America's largest energy
development projects, such as fossil fuel, nuclear, geothermal, and solar power generating stations; coal and uranium mines; energy transport systems; and the long-term impacts (to air, water, soils, and biological
systems) of fossil fuel emissions.
His scientific experience includes studies for the U.S. Forest Service and the U.S. Fish and Wildlife Service,
and for university, state and federal agencies, and private industries throughout North America. He has conducted scientific research on wildlife, forest ecology, natural ecosystems, endangered species, and
energy/environment relationships within over 30 states and provinces of Canada, and hence is uniquely
qualified as an ecologist with broad state, national, and North American expertise.
Regarding white-tailed deer (Pennsylvania's third big game mammal), Eveland was requested by the Minority Leader of the Senate, the Office of the Governor, and the Pennsylvania State Legislature's Game and Fisheries
Committee to conduct a comprehensive assessment of the Pennsylvania Game Commission's deer
management program.
John is an accomplished photographer of wildlife, wilderness, and the sea – including over 500 showings of his work, multiple national awards, and distribution of his work throughout America and worldwide. He is
founder and chairman of The Terra Cor Institution – a private, nonprofit organization dedicated to science,
education, environment, and the arts.
John Eveland can be contacted at 412.601.0077, and at [email protected].
ON A PERSONAL NOTE John Eveland
In 2000-01, I was asked by the senate minority leader to assess PGC's deer-reduction program, and again was
requested by the Office of the Governor and the majority leader of the House Game and Fisheries Committee in 2007. In 2010, members of PGC's Board of Commissioners asked me to prepare a new deer management plan
for them in the event that they could muster a majority of votes to halt the deer-reduction program. From my
investigations, I have come to two over-riding conclusions: (1) that no significant benefits have resulted after 14
years of herd reduction—not for science, forest or deer health, biodiversity, 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 radical environmentalists at the expense of sportsmen and
recreational hunting, and as such is in violation of PGC's mission and state law.
On a personal note, I am not a newcomer to forest and wildlife issues, and as a former Penn State scientist and
independent wildlife biologist I have had a long relationship with DCNR and the Game Commission. I admit that some of my dealings with PGC have not always resulted in the fondest of memories. In this regard, a former
PGC Commissioner wrote in an email: "Some of my good information from inside the PGC came from folks that
had paid their dues. They had 35+ years of PGC employment. They knew it all. I knew about John Eveland long
before his name came up in the (deer management) audit proceedings. John was the brains behind the PGC bear
program. Not Gary Alt. Gary Alt was handed the bear program on a silver platter. John was also the mastermind of the elk program. He handed it to Rawley Cogan, again on a silver platter. John was a marked man in the
PGC. He was never given credit for his accomplishments. There was real bad blood with John and the PGC.
John has enough info compiled to sink the PGC ship."
That said, I have always felt that the PGC was a capable and necessary state agency. Some of my best, lifelong friends have been employed by PGC and DCNR – foresters, biologists, WCOs, administrators, and board
members. I have sat in the homes of disgruntled WCOs and DCNR foresters contemplating resolution of the deer
reduction program, and they in mine. These are good and honorable people, and I believe that a few bad apples
should not be permitted to spoil the barrel. There are those in the legislature who desire to merge PGC with the
Fish and Boat Commission, some who wish to roll PGC into DCNR, and others who seek to end PGC's independent status by making it a department within state government – the Pennsylvania Department of Fish
and Game. In my mind, there would be great and lasting harm that could result for sportsmen and recreational
hunting – especially for deer management. It is my hope that the deer-management debacle can be resolved
without destroying the autonomy of the agency.
Some of the best days of my life have been spent hunting and fishing with my dad, grandfather, and brother. I
cannot bear the thought that these days have already ended for many families and will continue to dwindle for
many more because of the mismanagement of our deer herd – Pennsylvania's state mammal – for the dreams of
ill-advised foresters and environmental ideologues. I have been fortunate during my career to have not only
conducted Pennsylvania's vanguard research on both bears and elk, but to have also conducted forest, wildlife biodiversity, endangered species, and ecosystem research in over 30 states and provinces throughout North
America. Because of this experience, I have concluded that any scientific benefits to the ecosystem or biodiversity
that have resulted from deer reduction are few to nonexistent. After 18 years of over-harvesting does and fawns,
PGC has gained nothing. However, the agency has lost much: 200,000-300,000 sportsmen lost from the ranks of
hunters, empty hunting camps, untold bankruptcies and destroyed family businesses, a cumulative state loss of $10 billion dollars since 2001 that continues to increase at the rate of $500 million each year, nearly $100 million
in annual lost tax revenue, and silent woods in the fall – in many areas devoid of deer, gunshots, and hunters.
Considering this, I would be remiss to turn my back on sportsmen and citizens. I, therefore, choose to continue
in my pursuit to bring attention to this travesty until PGC's deer reduction program is resolved -- because it is the
right thing to do. It's time for common sense to prevail.
