ACA Update- May 7

Fellow cervid breeders and enthusiasts,



Below is a link to the latest ACA news update regarding the CWD Federal Standards Working Group. It can be also directly be found on the American Cervid Alliance website’s newsroom page.



http://www.americancervidalliance.org/news.cfm?id=39





Thank you and take care,



Travis

Travis, It seems there are issues that cannot be addressed in the standards document because the minimum is already included in the Rule. Essentially the Rule is law, more or less. Do you know the process for requesting changes to the rule? I have been told it is much more difficult to change the Rule than to making proposed changes to the standards. If these Standards are passed without changes for industry, will we then have to make proposed amendments to both the Standards and the Rule? This whole process is very confusing. Thanks.

This process is flawed and unfair simply because the deck is stacked against this industry since the wildlife agencies are still included for input. These wildlife agencies refuse to follow the same rules and regulations we follow but yet they have been allowed to influence unfair rules and regulations on this industry.



Also, while the states may still have the option to accept whatever USDA ends up approving, my concern is the states that don't accept it will not be allowed importation into the states that do accept it.



I feel that it will have to be challenged in court to get any relief.

Autry said:

This process is flawed and unfair simply because the deck is stacked against this industry since the wildlife agencies are still included for input. These wildlife agencies refuse to follow the same rules and regulations we follow but yet they have been allowed to influence unfair rules and regulations on this industry.



Also, while the states may still have the option to accept whatever USDA ends up approving, my concern is the states that don't accept it will not be allowed importation into the states that do accept it.



I feel that it will have to be challenged in court to get any relief.

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So true! Where have we heard this before!

We all know, litigation is last step. No other alternatives for changing the Rule? Another public comment period? Yes, David, I believe the importation and transit through states will be an issue, as both the Rule and Standards allow states to be more restrictive, if they so chose. Seems to me that because they allow states the right to do as they chose, we aren't gaining any grounds, just adding another layer of regulations on top of a bad Rule. How and why did these Standards even get started? USDA/wildlife or industry requested???

Rhonda Brakke said:

We all know, litigation is last step. No other alternatives for changing the Rule? Another public comment period? Yes, David, I believe the importation and transit through states will be an issue, as both the Rule and Standards allow states to be more restrictive, if they so chose. Seems to me that because they allow states the right to do as they chose, we aren't gaining any grounds, just adding another layer of regulations on top of a bad Rule. How and why did these Standards even get started? USDA/wildlife or industry requested???

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I believe the usda is on the lookout, The dec,dnr of states add false fuel to the fire and the industry leaders were working with them at the state levels to keep us all in business.

Word has it that Florida is now in the process of closing their borders!

Four Seasons Whitetails said:

I believe the usda is on the lookout, The dec,dnr of states add false fuel to the fire and the industry leaders were working with them at the state levels to keep us all in business.

Word has it that Florida is now in the process of closing their borders!

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Not surprised. Will probably be more as they try to meet requirements of the Rule. Expensive to state and producers just to comply.

Rhonda Brakke said:

Not surprised. Will probably be more as they try to meet requirements of the Rule. Expensive to state and producers just to comply.

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You bet ya and i believe untill every state that has dec,dnr involved in their..Farm's..goes to court and gets wildlife people out of Ag. Nothing good is going to change untill the right dept's are working within the right laws! Has to be done at a state level if the states are the ones that are going to make the rules at the end of the day!

Rhonda Brakke said:

How and why did these Standards even get started? USDA/wildlife or industry requested???

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I would like to hear ACA's answer to your question.

David

The first I saw of the standards document was in august at the NAEBA convention.Patty Klien gave a presentation on them and said she had wrote them,by herself without industry imput.Every producer that attended came out of the room against the standards as written.We were told the rule would be in effect in early Dec.Shawn was also at the meeting and seemed to know about standards Patty had written. Afterward Shawn and I had conversation in the hall. He said that the standards were not that bad and we could fix them later.Those standards he refered to at that time were prior to the working group ever being formed.Being a member of the ACA,the ACA was formed after the standards had been presented by Patty Klien.





Kim Kafka

NAEBA President

Kim Kafka said:

David

The first I saw of the standards document was in august at the NAEBA convention.Patty Klien gave a presentation on them and said she had wrote them,by herself without industry imput.Every producer that attended came out of the room against the standards as written.We were told the rule would be in effect in early Dec.Shawn was also at the meeting and seemed to know about standards Patty had written. Afterward Shawn and I had conversation in the hall. He said that the standards were not that bad and we could fix them later.Those standards he refered to at that time were prior to the working group ever being formed.Being a member of the ACA,the ACA was formed after the standards had been presented by Patty Klien.





Kim Kafka

NAEBA President

Click to expand...

Kim, Now it makes sense, as I found on the USDA Chronic Wasting Disease website:



http://www.aphis.usda.gov/animal_health/animal_diseases/cwd/cwd_q_a.shtml



"This is consistent with the proposed traceability rule and is described in the CWD rule, the CWD program standards, and on the traceability web site." Please see this site, the USDA answers questions about physical inventories, missed samples, and requirements for death reporting, etc. This was updated, September 7, 2012. I went to USAHA in October, as Laurie Seale, encouraged me to put a face with CWD. At USAHA I learned about the language in the Standards.



As I go through my notes, it was Laurie Seale, who pointed out to Patty Klein that passing these Standards without Industry input, may be illegal because of standard protocol for implementing these type of regulations had not been accomplished. It was after that meeting that our Resolutions were passed.



Of those Resolutions, the most important: "The US ASAHA urges USDA Vet Services to revise the document entitled, "Chronic Wasting Disease Program Standards", and establish a CWD Program Standards Committee to rewrite the document so that it more appropriately reflects the needs of producers and regulatory officials charged with implementation of a program to control, not eradicate, CWD in the United States." This is when the Standard Working Group was developed. It was Mr. Fischer (sp?) Wildlife, that wanted wildlife represented on the Standards Working Group.



While at USAHA, I was invited to speak to the National Assembly of State Veterinarians. Again, not a public speaker or leader, I requested they consider a control program rather than an eradication program in an environment with no indemnity, and no live test or vaccine to protect our animals, AND requested research.



Important to note, Charly Seale was very instrumental in getting support of the State Vets in helping to develop the Resolutions at USAHA. The ACA was not developed until after the October 2012 meeting at USAHA.



At USAHA the Executive Director to NADeFA was in favor of passing the Standards and working on them later. Obviously, I have CWD so I am in favor of a control program in an environment with no indemnity, a five year quarantine for our animals and land, and the loss of our hunting preserve.



It probably won't make a hill of beans for Tom and I what happens with this Program Standards, in our situation that is. If they come back unfavorable to industry, I hope you will all remember the girl who cried wolf.

So i have to ask. If someone knew that reguardless of a standard or a rule that the states themselves could make any rules or laws they wanted, Would it not have been best to work on each state, At the state level.

Kim,

Thanks for your reply.



Rhonda,

Since the wildlife agencies refuse to follow the regulations that this industry follows, THEY SHOULD NOT BE INVOLVED IN THIS PROCESS. These wildlife agencies only want to be involved so they can kill this industry.



People,

We're just spinning our wheels here. Refuse to negotiate as long as the wildlife agencies are at the table. This industry is not going to be treated fairly as long as these wildlife agencies are involved.

David



You are one of the folks who requested the industry to play the game and work to fix the document with the working group so that is what we are trying to do....now you are posting that we should throw the wildlife agencies off the working group and refuse to work with them...please make up your mind as you are confusing all of us. One minute you post that we should fight the overregulations and the next time you post you are glad to see we are trying to work on the standards document to fix it....once again I would say you are saying two different things. When some of us wanted to throw the document out and start over writing a new document with only industry and the state vets at the table, you criticized us severely.



You are giving me the impression that you support what we said and what we wanted to do but because it wasn't the right folks saying it you chose to attack those of us who wanted to fight the overregulations and do what we thought was best for the industry. You seriously need to put your personal agendas aside.



Laurie

I applaud Charlie Seale and whomever for getting the Standards Working Group going back in Oct. 2012. However, something remains unclear. Did John Fischer ask to become involved? Did anybody know John was going to pick two (Cal Bubrock and Dale Garner) DNR persons very unfriendly? Or was John Fischer asked to be involved?



It happened right here in this USAHA resolution.





UNITED STATES ANIMAL HEALTH ASSOCIATION 2012 Resolution ___________________________________________________________________________







RESOLUTION NUMBER: 24 APPROVED







SOURCE: COMMITTEE ON CAPTIVE WILDLIFE AND ALTERNATIVE LIVESTOCK







SUBJECT MATTER: CHRONIC WASTING DISEASE PROGRAM STANDARDS







BACKGROUND INFORMATION:



It has been stated by the United States Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS), Veterinary Services (VS) that the goal of the Chronic Wasting Disease (CWD) program in the United States has now changed from eradication to controlling its spread.



The document entitled, "Chronic Wasting Disease Program Standards" was published by USDA-APHIS-VS in July 2012. It was developed before the shift of the CWD program from eradication to control and without adequate input from state wildlife and animal health officials or farmed cervidae producers. Sections of the document suggest placing restrictions on farmed cervidae producers that do nothing to further the effort to control the spread of CWD. The restrictions are not based on current scientific knowledge and could undermine the success of CWD control programs that have been in place in many states for more than a decade.







RESOLUTION:



The United States Animal Health Association urges the United States Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS), Veterinary Services (VS) to revise the document entitled, "Chronic Wasting Disease Program Standards", and establish a Chronic Wasting Disease (CWD) Program Standards Committee to review and rewrite the document within 90 days so that it more appropriately reflects the needs of producers and regulatory officials charged with implementation of a program to control, not eradicate, CWD in the United States.



The United States Animal Health Association suggests that the CWD Program Standards Committee should be made up of representatives from and appointed by each of the following organizations: (1) the Exotic Wildlife Association, (2) the North American Elk Breeders Association, (3) the North American Deer Farmers Association, (4) the Association of Fish and Wildlife Agencies, (5) the National Assembly of State Animal Health Officials, and (6) the USDA-APHIS-VS.UNITED STATES ANIMAL HEALTH ASSOCIATION 2012 Resolution ___________________________________________________________________________







INTERIM RESPONSE:



The U.S. Department of Agriculture, Animal and Plant Health Inspection Service, Veterinary Services (VS) recognizes the concerns of the United States Animal Health Association (USAHA) and appreciates the opportunity to respond. To address a number of concerns voiced at the 2012 USAHA meeting, VS established a CWD Program Standards Working Group. The goal of the working group is to discuss stakeholder concerns with the CWD program standards and to recommend revisions as necessary. The group is composed of three representatives each from the National Assembly, the Association of Fish and Wildlife Agencies, and the cervid industry; two representatives from the American Association of Veterinary Laboratory Diagnosticians; and experts from VS.



The working group first met on November 28, 2012, and continues to have weekly teleconferences. We expect revisions to the program standards to be completed by the first week of March. The revised program standards will then be made available for public comment through a notice in the Federal Register.

Mike,

Some of us wanted to do away with the whole program and go back to the individual state's rules because of how bad we thought the federal rule and the standards were....some of us believed we were better off with our state rules than what we ended up with on the federal level....especially given the fact that all the federal funding disappeared and now we are stuck with an unfunded mandate....those of us who wanted less regulation ended up with the short stick and had to agree to try and fix what was wrong with the document instead, therefore we are doing our best to help fix a bad situation....I believe in the democratic process.



When we first asked for a federal CWD rule, USDA was preempting state's rights and all state borders were going to be open to free trade...all states were going to be on the same level playing field....that all changed in 2009 and now all states can make their rules as stringent as they want.....not what we had hoped for in the beggining of this rule making process.



Laurie

Laurie,



You and I both know that the wildlife agencies are doing all they can to destroy this industry and they should not be allowed to be part of this process since they are unwilling to abide by the same rules.



Only if they are willling to abide by the same rules, then they should be allowed to have a say in this process.

Dwight,

I don't believe the wildlife agencies were included in the original resolution, but because they are part of the committee they also have input in what the final resolutions state, they made the request to be included in the working group. Dr. Clifford also stated when we were in DC that he thought they needed to be at the table so we have to make the best of it at this point.

Laurie

David,

You ignored what I wrote....this working group has not choice but to work with the wildlife agencies...you just posted today that you were happy EWA and NAEBA agreed to work on finishing the process with the standards....that is what everyone is doing right now so it does no good for you to keep saying to stop working with the wildlife agencies...you are saying two different things and we have no choice at this point but to work with them.

Laurie

Laurie,



Can wording not be added that would hold the wildlife agencies to the same rules they are promoting? Otherwise, we are just spinning our wheels here.