Firm Urges National Park Service To Prepare A Supplemental Environmental Impact Statement Before Killing Any More Deer In Rock Creek Park

On behalf of a group of individuals who live near Rock Creek Park in Washington, D.C., we sent a letter to the National Park Service asking it to prepare a Supplemental Environmental Impact Statement before killing any more white-tailed deer in the Park this year and in the future.  When the Park Service decided to initiate its lethal control program in 2013 – the first time it killed any native wildlife in this National Park since its establishment over 120 years ago – it purportedly based that decision on the belief that the deer were interfering with the regeneration of native vegetation in the Park and said it wanted to reduce the deer density to between 15 to 20 deer per square mile, which the Service claimed would allow for “successful forest regeneration.”  Our clients argued unsuccessfully that the problem was not an over-population of deer but that the Park has for decades been overrun by invasive non-native plant species, many of which originate from private and commercial landscaping that surrounds the Park. Now, after three years and the killing of hundreds of deer, we have learned from records obtained under the Freedom of Information Act that the deer density is only 19 deer per sq. mile – i.e., it is now within the Park Service’s desired range -- yet there is no evidence that the reduction of deer has had any impact whatsoever on native forest regeneration.  At the same time, the non-native plant species continue to proliferate throughout the Park unabated. Because agencies have an obligation under the National Environmental Policy Act (NEPA) to rethink actions that have a negative impact on the environment if circumstances change or new information shows that the action is no longer justified, we have asked the Park Service to prepare a Supplemental EIS before killing any more of this native wildlife.  A copy of the letter can be found here.