RE: PA DEER AUDIT UPDATE.....
"us that both proposals submitted by WMI are virtually identical and do not provide for field analysis of
habitat, forest regeneration or surveys of deer population. Instead the WMI proposals, and indeed all
of the proposals except the Eveland proposals, rely on data gathered and submitted by the
Pennsylvania Game Commission with ‘zero’ field work. This negates the spirit and intent of calls for
an independent study of this issue.
If it is the intent of the audit to simply answer questions regarding the ‘scientific’ nature of certain
concepts then ‘all’ of the submitted proposals will accomplish that. However ‘if’ it is the desire of the
legislature to address the concerns of their constituents, sportsmen and women and our heritage of
hunting, then there is only one study submitted thus far, Mr. Eveland’s, that will accomplish these
goals.
In addition, the Levdansky, Schaeffer, WMI Audits use PGC data with PGC assistance, PGC
personnel will accompany the auditor, the audit will not involve scientific field studies, PGC will be
presented with the draft prior to legislators, and PGC will make comments and changes to the audit.
This is not our view of independence and autonomy on the part of auditors reviewing the conduct and
actions of others.
Having waited for over a decade for these concerns to be addressed we implore this committee to
hold hearings for stakeholders to testify on these proposals. At a minimum, to allow each entity
submitting proposals to be offered the opportunity to present open testimony to the Legislative Budget
and Finance Committee that will be a matter of public record.
To restate the desires and requests of the 17 groups/organizations (May/2007 letter) involved in
calling for an audit we insert the selected sections below as a reminder:
. . . Instead, we suggest that you call for a transparent examination of the methods and data
used by the Game Commission to measure and make decisions on harvest reports and the three
factors of habitat condition, deer health, and deer-human conflicts.
. . . We also suggest expanding this analysis to the field to examine actual habitat conditions
on Game Lands and other representative properties within select Wildlife Management Units
so that legislators and the public can better understand deer densities and habitat conditions.
A rush to judgment and implementation of a proposal that does not adequately address the concerns
of all will only worsen the divide and distrust for the entire process. This we cannot afford!
Respectfully submitted,
Kim Stolfer