Make NPS show deer data before Richmond Battlefield's plan advances

The agency’s case, tested

What the agency argues, and whether its own record backs it

5

No support given

Each Ask below goes into your letter when you write it with PLAN on this page, matched to what you tell it about how this land reaches you.

• Purpose and need

  No support given

  The park has too many deer, and that overabundance needs to be managed.

  The agency's support is its list of overbrowse impacts on forests, wildlife habitat and earthworks. The document gives no deer count, density estimate, survey year or method. It also never says what deer level the park would consider sustainable. So it states that there are too many deer but never measures it.

  AskPublish the park's deer counts or density estimates, with survey methods and years, and the density the park considers sustainable, before the draft plan and environmental assessment come out.

  The agency’s words +Hide the words

  The agency says

  “The plan is needed to manage the impacts of deer overabundance in the park.”

  What is the purpose of adaptive white-tailed deer management in Richmond National Battlefield Park?

• Effects

  No support given

  Deer overbrowse is hindering preservation of the forest understory, earthen trenches and fortifications, and the 1862 and 1864-65 battlefields' forest-field layout.

  The strongest support is a photo with the caption "Deer trail damage to earthworks." Apart from that one image, the document doesn't say where the damage is, how widespread it is or how it was measured. It doesn't say how the battlefields' forest-field layout has changed, or how the park told deer effects apart from other causes.

  AskMap and measure deer damage to earthworks and battlefield landscapes, say how widespread it is, and explain how the park separated deer effects from other causes.

  The agency’s words +Hide the words

  The agency says

  “Deer overbrowse (i.e., too many deer eating too much vegetation) inhibits preservation and maintenance of character-defining features, such as the forest understory, earthen military trenches and fortifications, and the forest-field configuration of the 1862 and 1864-65 battlefields.”

  What is the purpose of adaptive white-tailed deer management in Richmond National Battlefield Park?

• Effects

  No support given

  Deer browsing changes the vegetation enough to reduce habitat and food for other native wildlife.

  The document shows a photo of a pine warbler but doesn't say whether that species is affected. It names no wildlife species that are losing habitat or food, and it gives no wildlife survey or population trend. The claim rests on a general explanation, not on data from the park.

  AskIdentify which native wildlife species the park believes are losing habitat or food because of deer, and provide the survey data behind that finding.

  The agency’s words +Hide the words

  The agency says

  “Native vegetation and wildlife diversity is at risk because deer overbrowse changes vegetation structure and composition, decreasing habitat and food for other native wildlife.”

  What is the purpose of adaptive white-tailed deer management in Richmond National Battlefield Park?

• Show 2 more claims +Show fewer

  • Effects

    No support given

    Heavy deer browsing on native plants lets invasive species take hold and spread in the park.

    The document lists invasive species among the threats to the forest twice. But it never names an invasive plant, says where invasives are growing or how fast they're spreading, or gives evidence that deer browsing is what's driving their spread.

    AskName the invasive plants involved, report where and how fast they're spreading, and explain the evidence that deer browsing is driving their spread.

    The agency’s words +Hide the words

    The agency says

    “Increased deer browsing pressure on native vegetation also allows invasive species to establish and spread, exacerbating habitat effects and resource availability.”

    What is the purpose of adaptive white-tailed deer management in Richmond National Battlefield Park?

  • Science

    No support given

    Many of the park's forest species are stunted or missing because of deer browsing, so the forest won't be able to replace its canopy.

    The document backs this with a general statement that seedling and sapling survival is reduced. It doesn't name which species are stunted or absent. It gives no seedling or sapling counts, survey plots or trends, and no comparison areas showing that deer, and not something else, are the cause.

    AskRelease the seedling and sapling survey data, name the affected species, and show how the park linked their decline to deer browsing.

    The agency’s words, the record and the law +Hide the words

    The agency says

    “Many of the park’s forest species are stunted or absent as a result of deer overbrowse, resulting in altered plant composition, insufficient understory growth to replace the forest canopy in the future, and increased forest vulnerability to disturbances such as storms, pests, and invasive species.”

    What is the purpose of adaptive white-tailed deer management in Richmond National Battlefield Park?

    Elsewhere in the same document

    “Forest regeneration is at risk due to reduced survival of seedlings and saplings.”

    What is the purpose of adaptive white-tailed deer management in Richmond National Battlefield Park?

    The law

    “ensure the professional integrity, including scientific integrity, of the discussion and analysis in an environmental document; (E) make use of reliable data and resources in carrying out this chapter;” National Environmental Policy Act, 42 U.S.C. 4332(2)(D)-(E) ↗

Read from the agency’s own decision document ↗, all 2 pages. Every quote is checked word for word against it, a claim marked contradicted stands on a quote from the same document, and a second reading argued the agency’s side of every verdict before it was published. The verdicts are our reading; the quotes are the agency’s. A court can set aside agency action it finds “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law” (5 U.S.C. 706(2)(A) ↗), which is why these gaps are worth putting in the record.