Excerpts from state wildlife agency comments on proposed
updates to USDA/APHIS Chronic Wasting Disease program
19 state wildlife agencies and the Association of Fish & Wildlife Agencies (AFWA) recently submitted comments regarding proposed changes to the USDA/APHIS CWD Program. Below are excerpts from those comments. Full comments from each agency are available online via the link found below the agency name.
These agencies represent the public interest in healthy wildlife, and responded with the input of their trained professionals — the soldiers on the front line of the battle to protect wild cervids like deer and elk from CWD.
The excerpts show clear frustration with the lack of federal will to turn this dangerously failing program around. The USDA has not proposed the hard changes needed. Instead the USDA has prioritized short-term industry interest over disease eradication — an unjustifiable break with other USDA disease programs and a violation of the public trust.
The cost of managing CWD in wild deer is borne by these publicly funded state agencies. The count of CWD states is 25 and growing. Currently nearly half of US taxpayers live in a CWD state. The costs are massive and will rise as CWD spreads — an urgent matter of clear public interest.
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"... prioritizes short term continuity of business objectives over the long term health of captive and wild cervids."
"… this is a flawed construct because it ignores the collateral damage sustained by wild populations of cervids when control of the disease is not the primary objective."
"... revisions do not address … well-known, significant shortcomings of this program."
"...based on basic precautionary principles of risk management that all species of the family Cervidae be considered at least potentially at-risk for CWD."
"Because the program is voluntary for those who do not ship animals interstate, it remains very ineffective."
"The steady stream of new detections of CWD at supposedly low-risk deer farms ... casts considerable doubt on the effectiveness of the CWD HCP overall..."
"... continued discovery of new infections within captive cervids, despite APHIS-VS efforts, makes it clear that the current and proposed HCP do not effectively minimize the risk …"
"We are not aware of any other USDA APHIS disease control programs that rely solely on testing of deaths that occur on-site and we regard it as a critical weakness..."
"... there is a precedent within the USDA Veterinary Services to make programs mandatory, and until that step is taken, we will not halt the interstate transfer of this disease.
"... the ... Program continues to fall short of minimizing the control and spread of CWD."
... CWD continues to be identified in USDA herd certified deer farms, which highly increases the probability that infected animals are being widely transported across the United States."
"... CWD has spread to new areas and continues to be found in herds that have met the requirements for interstate movement (5 herds in 2018)."
"... the 5 year time period is not long enough to certify the herd as low risk …"
"… as no method has been proven to be effective for environmental decontamination, premises should be restricted from introducing cervids after depopulation."
"The efficacy of turning soil in pastures or of removing 1 to 2 inches of soil in dry lots has not been evaluated. … such practices may give producers a false sense of security."
"... ALL cervid species … should be included in the program standards."
"The 5-year cutoff proposed ... is not consistent with data demonstrating environmental persistence and incubation periods for CWD or other prions that are greater than 5-years."
"Double fencing should be required ..."
"...stricter disinfection, quarantine, and depopulation rules are required."
"... standards still fall short ... the goal should be eradication from farmed cervids."
"The goal ... should be eradication of CWD from captive herds…"
"... standards seem to focus on lowering the risk of CWD transmission while allowing interstate transport of live cervids, rather than actually controlling the disease."
"... program standards should be mandatory..."
"The 5-year quarantine period ... following detection of CWD is inadequate."
"...all members of the cervid family should be subject to the … Program Standards."
"CWD positive herds should be depopulated as soon as possible."
"... the Program Standards were written to favor the continuation and increase in captive cervids."
"... CWD continues to be found in captive cervid herds that have met the requirements for interstate movement ..."
"Annual physical inventories should be required because of the high rate of movement between breeding operations and hunting preserves."
"... it is clear from the number of certified herds in which CWD has been detected that the 5-year time period is not long enough ..."
"When fences are replaced, facilities should be required to install fencing that is at least 10 feet tall and to install secondary barriers."
"Escapes and incursions of wild cervids should result in demotion of the herd status."
"... state wildlife agencies should be included in all notifications regarding the detection of CWD in farmed cervids. "
"... as no method has been proven to be effective for environmental decontamination, premises should be restricted from introducing cervids after depopulation, potentially forever."
"The use of a live animal test with at best a 70% sensitivity to qualify a herd for removal from quarantine and reestablishment of full HCP status is not recommended because of the likelihood of missing a positive animal."
"... the failure of this disease control program lies with inadequate testing and the continued movement of animals across state lines."
"A mandatory program where all farmed cervids over 1 year of age are tested upon death, required permanent marking of animals over 6 months of age, and sufficient recordkeeping to trace an animal from birth to death would greatly increase the likelihood of control."
"We regret that APHIS was not able to take a stronger stance by requiring double fencing, or secondary electric fencing..."
"... the loss to follow up of deer shipped to hunting preserves is a major deficiency of the CWD program."
"We recommend … mandatory testing of all cervids shipped to hunting preserves.... If these measures are not taken, ... USDA will not … achieve their program goals..."
"... depopulation should still be the primary consideration for herds where CWD was detected to minimize risk of disease incubation, shedding, and spill-over to wildlife..."
"... search for novel approaches for indemnity funding, including placing the burden on the industry…, which derives profits from the hunting and breeding of captive cervids."
"... this producer-centric approach is not in line with the mission of APHIS to ‘protect the health and value of American agriculture and natural resources,’..."
"… the program is very ineffective. … No other major USDA APHIS interstate disease campaign in history has been voluntary."
"While indemnification ... is provided for captive cervid farmers, no monies are provided for state wildlife agencies to handle CWD in the wild population, even though translocation of cervids is a primary source for wild deer infection."
"Utilizing U.S. taxpayers' funds to depopulate an infected captive herd, then allowing the contaminated site to be repopulated is a serious misappropriation of these funds."
"Purposely neglecting to test clinical deer … is of paramount concern. Allowing the pen owner to 'replace' the sample ... does not compensate for missing a potentially infected animal; this is playing games with serious economic and biologic consequences."
"... some states allow wild caught cervids to be reduced to ownership in pens. Interstate movement of wild caught cervids may constitute a Lacey Act violation. … USDA' s blatant disregard for the Lacey Act is cause for extreme concern by LDWF."
"Depopulation ... is a business risk that can be covered by the business through ...insurance coverage…"
"... ante-mortem testing must be removed as a valid option for HCP status."
"... many of the proposed changes … significantly increase the threat of CWD introduction ... through interstate movement of captive cervids."
"MDNR regards CWD as an unparalleled threat to ... cervid populations"
"... inconsistent with sound disease control and epidemiologic principles used with other program diseases and do not adequately address the complex nature of the prion..."
"... more stringent testing requirements for all privately-owned cervid herds, including those not enrolled in the Herd Certification Program."
"... it is inappropriate to allow 'Certified CWD Sample Collectors' ... without qualifications... This is not allowed in other program diseases ... such as bovine tuberculosis or brucellosis…"
"... inclusion of State wildlife agencies in the development and approval of herd plans."
"... annual HCP reports be shared with state wildlife agencies…"
"...inclusion of State wildlife agencies in the reporting of cervid escape and ingress incidents in POC facilities."
"... USDA has the authority and justification to mandate post mortem testing of all captive cervids and should take immediate steps to amend its regulations."
"Revisions continue to allow states to approve owners as certified … (CWD) sample collectors. This is a major loophole in ensuring integrity of the HCP program."
"There is no closure of the Big Game Hunting preserve loophole for surveillance. … this omission is serious..."
"...prioritization of herds for depopulation ignores the great risk that CWD-infected hunting preserves present to spillover of the disease into free-ranging cervids."
"... while the stated goal of the program is disease control, many … provisions do not work towards this end. A voluntary program has proven to be ineffective..."
"...standards fall short in protecting the captive cervid populations… this puts our free-ranging populations at risk as collateral damage."
"...this document ... is lacking ... the true concern over the impacts to wildlife. There is mention of cooperative efforts but often it seems as wildlife are an afterthought ..."
"CWD is a disease caused by a prion. Why is it not treated like every other prion disease for which the USDA has established program goals?"
"... standards allow for greater risk by … 1. not improving fencing requirements … 2. allowing for continued environmental contamination on premise .... 3. inadequate testing"
"… allows ... herd owners to collect their own samples if they are certified. This … is inconsistent with most other disease programs."
"...(NHF&G) does not feel that the program standards, as written, are sufficient"
"...little has been done to address ... concerns states have expressed about the Program Standards over the years. The Standards have been relatively ineffective to date"
"Physical inventories should be conducted at least on an annual basis..."
"... record keeping ... one of the biggest shortcomings ... records should be kept for 5 years after all enrolled cervids’ deaths, regardless of where the cervid dies."
"Testing should be required for any animal ... sent to a shooter and/or slaughter facility."
"...Program Standards do little to address the long standing disease transmission issues related to the captive cervid industry..."
"...Program Standards are not meeting the original APHIS objective..."
"...animals from a Certified herd may be shipped interstate. We know this is a possible avenue of introduction or movement of CWD into a state or within a state."
"...CWD has been found in a number of … CWD Certified Herds"
"...a prion is an extremely resilient and robust pathogen that can contaminate the environment and remain infective beyond five years."
"... it is not possible for APHIS to make the claim that their objective is 'to control the incidence of CWD in farmed cervids and prevent the interstate spread of CWD' ... until all cervid hunt facilities are included in ... a comprehensive nationwide ... program."
"... stakeholders who have ... interest in the health ... of wild cervids … and a healthy disease-free environment were not fairly represented on the CWD Working Group. This is a huge stakeholder group and they are significantly underrepresented…"
"... failing to factor in the severity and long-term consequences of the introduction of CWD
into wild cervid populations..."
"APHIS should have proposed the most rigorous, most conservative, and most effective CWD Program Standards to meet the actual threat posed by CWD.... That did not happen."
"Until these regulations are revised..., no state agency should allow the importation into their state of any … cervid from any CWD Certified Herd."
"... herd inventories should be conducted every year… it is critical to physically account for the animals in a herd each year..."
"It is inconsistent with sound disease management practices to allow an animal suspected
of having CWD to be monitored until death. … One animal could be the source of infection for an entire herd..."
"...it is inconsistent with sound disease management practices to allow animals in a ... herd that is under quarantine to be moved...."
"... include state wildlife agencies in the process especially when reporting any CWD-positive, CWD-exposed, or CWD-suspect cases..."
"...require that the HCP include ...: a. ... insurance that will cover the loss of all captive animals in the event ... animals are required to be depopulated... b. ... a valid performance bond to cover the costs associated with the escape of captive cervids..."
"... it should not be an option to allow a CWD-positive herd to remain on the environment shedding prions."
"... prohibit onsite burial for CWD-positive, CWD-exposed, and CWD-suspect carcasses. Onsite burial does not inactivate the prions and poses a direct and persistent threat for environmental, surface water, and ground water contamination."
"... decontamination protocols must be revised and significantly enhanced. 'Hot water and detergent' is NOT an effective decontamination protocol for prions."
"...as a voluntary and advisory program lacks sufficient authority..."
"One of the stated outcomes of this program is a 'strong trade of cervid animals and
products'. While the trade of non-native cervids may be desirable to USDA/APHIS, the trade in native wildlife is contrary to the North American Model of Wildlife Conservation, which is a guiding principle for the ODWC"
"The current and proposed testing standards are inadequate to effectively monitor and detect CWD. … More rigorous ... testing is warranted to protect the nation's wildlife. "
"A 30 foot buffer is suggested … to prevent commingling of captive animals, yet no such suggestion is in place to protect against captive and free-range cervid disease exposure … double fencing should be equally, if not more, important to separate captive animals from free-ranging native animals. "
"As the prions remain active in soil and on other surfaces, the ODWC suggests that all future cervid stocking be prohibited at CWD positive facilities and that a barrier fence sufficient to prevent wild cervid access be erected and maintained."
"it is our recommendation that all animals killed at a shooting facility be tested regardless of source herd/kill facility ownership relationship. "
"ODFW does not believe the desired outcomes of the proposed standards will be achieved."
"Since the beginning of this year, CWD has been found in nine new captive herds, five ... certified as low risk…"
"The proposed revisions … will continue to facilitate the spread of CWD…"
"...does not demonstrate the combination of protocols, strategies, or guidance that will result in the reduced risk of CWD in captive or wild populations"
"It is not possible to see how USDA will … reduce the risk of transmission from positive herds, while there continues to be new positive HCP facilities..."
"... likely provided a regulatory mechanism to facilitate the spread of CWD."
"Why allow non-accredited non-veterinarians to collect and submit as part of this program … a standard that allows potential bias and may be a factor in why most of the … trace outs by USDA have led to inconclusive results …"
"...the national program allowing interstate movement should cease transport approvals until the program can ... demonstrate effectiveness."
"... continued [human caused] spread of CWD is hastening the impacts to ... wild herds..."
"The loss of wildlife ... due to poorly conceived ... programs … equates not only to the health … of populations, but also to ... communities that depend on wildlife as a resource."
"Why is the reporting period involving out of state traces 45 days? ...this would ... allow new infections to be spread among high throughput facilities. "
"It would seem prudent not to allow the practice of shipping germplasm [semen, embryos] … until this has been tested and vetted in peer-reviewed research. Prions are … transmitted in germplasm products in related diseases like scrapie."
"...standards continue to provide a major loophole for CWD to spread occurs by allowing animals from certified herds to be moved and not tested."
"... certified herds that test very few animals … because of their practice of high throughput or sale of animals at an early age. This is one of the most serious faults of the proposed program standards."
"...facilities that become positive for CWD should lose their status ...permanently…"
"... USDA should revoke ... a facility's HCP status if an owner is convicted of, or admits to a violation of … animal transportation or livestock laws related to the captive cervid facility"
"...allowing a replacement animal for a missed sample provides another avenue to confound the true disease status of a herd..."
"Preventing one CWD positive animal from infecting a new area or state is well worth a nationwide restriction on interstate captive cervid movements..."
"Infected facilities should be considered contaminated with full quarantine until research or technology is able to define the period required (10 years, 25 years, etc.)"
"Restocking ... following the incidence of CWD ... should be banned due to … probability that the restocked animals will contract the disease..."
"...the program … continues to put ... free-ranging North American cervids at risk."
"Similar to the 2014 version, the 2018 draft provides a regulatory instrument for the captive cervid industry to move infected animals intra- and interstate."
"The Game Commission regards … CWD … as a serious threat to … wild cervid populations..., and strongly supports efforts to control CWD in captive cervids..."
"... we have grave concerns that the proposed revisions are not stringent enough to minimize the risk of CWD or the rate of its spread throughout the country."
"... proposed revisions do not provide strict enough biosecurity or surveillance standards to prevent new infections or control disease…"
"...proposed revisions deviate from basic disease control and epidemiologic principles used with primary agricultural animal species (i.e., cattle, swine, and poultry) and completely ignore existing information on CWD."
"...proposed revisions ... are not consistent with ...a disease control program."
"...these revised CWD Program Standards will continue the trend toward less stringent regulations.... Consequently, the … long-term goals the HCP are unlikely to be successful."
"... numerous examples of HCP herds within Pennsylvania that test very few animals over a 5-year period but remain compliant with the 100% mortality testing requirement."
"... escapes occur frequently in Pennsylvania. Five hundred documented escape events involving nearly 1,600 animals have occurred over the past 10 years… . These likely represent a fraction of the actual escapes as evidenced by numerous cases where our game wardens dispatch ear-tagged animals for which there is no traceable identification."
"... the response to CWD positive herds has degraded to the current system that no longer achieves any of the listed goals or objectives of the HCP."
"The lack of … indemnification funding is the primary reason given for the failure to
depopulate CWD positive herds. Even when ... available, the process can take several years and … is of limited value other than a financial gain for the cervid propagator..."
"The ignoring of environmental exposure to CWD ... is an obvious critical oversight, and one that likely has contributed to the ineffectiveness of the HCP."
"... revisions appear as strict or less than the already lenient, and proven inadequate … Standards. These ... continue the ... focusing on minimizing inconvenience for cervid operators while avoiding … practices to protect both the industry and wild cervids..."
"… Of great concern is the potential impact of CWD on free-ranging cervid populations...."
"The primary focus of the CWD program should be on disease control... rather than assuring business continuity."
"A goal in the ... (HCP) should be to prevent any … spread of CWD, rather than limiting the focus to the interstate spread of CWD."
"... CWD can be detected in uterine tissue. Artificial insemination ... is a commonly used procedure in deer breeding operations … we are concerned with the possibility of transmitting CWD between facilities via contaminated instruments."
"Animal identification is an integral component of disease management. … The options allowed under current identification rules include methods that are not reliable..."
"...means of identification [should] remain with the animal throughout its life, regardless of ownership of the facilities where animals are transferred."
"... certification involves only the testing history within the facility and/or the source of animals ..., but does not consider the history of the ground on which the facility exists."
"Testing should be required for all animals regardless the cause of death."
"...Replacing the more valuable sample with a producer-preferred sample from a seemingly healthy deer is a significant reduction in the quality of the surveillance program..."
"Consideration should be given to … restrictions on movement of possible CWD-contaminated materials such as antler velvet, antlers, semen, embryos, etc."
"...indemnity should not be the determining factor for depopulation … waiting ... to determine status allows the disease to remain on the landscape longer."
"TPWD has experienced many situations ... where gates were left open or perimeter fences were otherwise compromised, explaining the disappearance of many deer. During the past 10 years, more than 10,000 deer were reported as escaped or were otherwise missing from 766 different Texas deer breeding facilities."
"Allowing a contaminated facility to maintain a herd inventory certainly increases the risks of CWD being introduced to the surrounding free-ranging cervid population."
"... physical inventories … be required every year… The high rate of cervid movement ... could result in a large number of animals residing on a farm for a short period of time and never being included in a physical inventory."
"... double-fencing ... a requirement ... as well as an 10 foot minimum fencing..."
"... the shooter preserve loophole ... still exists in the Program Standards."
"...require all herds ... to test every animal over 12 months of age that leaves the facility,
dead or alive, including all cervids that are transported to any shooter/hunting preserve."
"... ante-mortem tests should be used as herd-based monitoring only, ... and should not be used to "certify'' individual animals as fit for movement to another facility."
"... herd plans should be required to include a time frame for which contaminated premises may not contain cervids after all CWD-positive, exposed, and -suspect animals have been removed; and … should include restrictions on use and movement of potentially contaminated livestock equipment."
"In whole document, wildlife seems to be considered least..."
"It is not clear how current program standards are being seen as CWD eradication when not all cervid farms have to be involved..."
"There have been cases of HCP enrolled facilities that had escapes that were later identified as Positive facilities and only then noted a loss of animals."
"If 30 feet or greater is required to delineate individual captive herds from one another, why is there not the same requirement to delineate a captive herd from a wild herd? This appears to be a double standard."
"Current writing allows ... herd owners to collect their own samples if they are certified. This is inconsistent with most other disease programs."
"Ante-mortem biopsy of WTD MRPLN: … equipment cannot be sterilized following this procedure, will there be rules regarding disposal to ensure no iatrogenic transmission?"
"... Does not incorporate … sources such as: tools used in Artificial insemination, Embryo Transfer, Semen Collection (urine contamination), pasture furniture purchased used, transport companies used to move animals, etc. Without these ... the epi investigation seems to be missing a large swath of information."
"...prions are likely to reside and be infectious in the environment for longer than 5 years, that process [quarantine] - shouldn't be shortened..."
"There should be no … depopulated facility ... allowed to restock immediately with CWD susceptible animals. The 5 year fallow is likely too short … Our recommendation is that susceptible cervids are never allowed on these premises."
"...the transfer of regulatory authority for captive cervids to the West Virginia Department of Agriculture … has clearly highlighted weaknesses of the current HCP Program ..."
"The changes proposed ... are still deficient from a disease management perspective and potentially jeopardize free-ranging and captive cervids within West Virginia."
"...proposed program standards do not provide a State with the ability to properly evaluate
the risk of introducing CWD."
"… there have been fence failures and escapes in West Virginia during the last year but the facility was not penalized. ...also … captive cervids escape from Ohio and Pennsylvania and end up in West Virginia. You must make mandatory penalties for such offenses."
"...program standards allow for the live movement of CWD-positive, CWD-exposed and CWD-suspect animals from the origin facility. Any movement of these live animals increases the risk of spreading CWD and should not be allowed for any reason."
"Testing should be required for all animals regardless the cause of death."
"...program standards do not include all members of the deer family that can be infected with CWD. ... all members of the cervidae family should be included …"
"... reporting of CWD-positive animals ... should include the respective State Wildlife Agency"
"... we ... urge USDA APHIS to address CWD ... from a science based disease … elimination process, rather than as a pro-industry initiative."
— end —
These excerpts were taken from the comments submitted by all 19 state wildlife agencies that responded to the USDA/APHIS CWD Program comment period. All state wildlife agencies are members of the Association of Fish & Wildlife Agencies (AFWA).
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