Below you will find Michael Butler's CWD comments. He is one of the guys that were trying to import elk for a restoration project that did not meet state or federal import regulations. The Coalition proved that the elk did not qualify for importation due to disease issues and improper testing and monitoring. USDA then stopped the shipment a couple of days before they were to be loaded on the trailers.
TN Wildlife Resources Agency, TN Wildlife Federation and the Rocky Mountain Elk Foundation were all part of this illegal attempt to import elk from Canada and KY that did not meet state and federal regulations. As you can see from Butler's comments, they want a double standard whereby Government Wildlife Agencies can freely move elk with little or no testing but captive raised cervids need to be tested to death according to Butler.
Butler has come to be known as the man that sunk the ship and about 200 elk were lost. Had it not been for the fact that he was bragging on an Internet site about the up-coming risky elk importation, the Coalition would not have known about it in time to prove the elk did not qualify for importation. Loose lips sinks ships.
***************************
http://www.regulations.gov/#!docketDetail;rpp=250;so=ASC;sb=postedDate;po=300;D=APHIS-2006-0118
August 13, 2012
Dr. Patrice Klein
Senior Staff Veterinarian
National Center for Animal Health Programs
Veterinary Services, APHIS
4700 River Road, Unit 43
Riverdale, MD 20737
RE: APHIS-2006-0118
Dear Dr. Klein,
The follow comments are preliminary comments of the Tennessee Wildlife Federation as they relate to the proposed Chronic Wasting Disease Herd Certification Program and Interstate Movement of Farmed or Captive Deer, Elk and Moose. We will follow these comments with more detail comments and information on this and related issues to the proposed rule.
The stated purpose, as we read this revised proposed rule, is to “establish a herd certification program for herd owners and States to control the incidence of CWD in farmed and captive cervids and prevent the interstate spread of CWD”. Keeping this in mind, we do not feel that this proposed rule will successfully meet to USDA-APHIS stated goal. Our specific comments are as follows.
1. This proposed rule appears to largely ignore the realities and threats that captive cervid operations pose to native wild cervids and the tens of billions of dollars of economic impacts that wild cervids provide to rural economies across the United States. While it makes sense that USDA-APHIS would focus upon helping herd owners and States control the incidence of CWD, we ask how USDA-APHIS can achieve its stated goal without a broader coordination with state wildlife agencies and interests and the realization that CWD poses a significant threat to these wild cervid populations.
2. “Herds that do not have any CWD-infected or CWD-exposed animals for 5 years will be granted Certified status” – The 5-year timeframe being applied in this rule appears to be insufficient to prevent the spread of CWD. Currently, there is no known incubation period for CWD and there are examples of cervids which have been infected and did not present symptoms until after they had passed the 5-years age threshold. Thus the 5-year time frame appears insufficient and should be modified to a longer timeframe that reflects the current knowledge of CWD incubation periods.
3. It appears that USDA-APHIS, via the language of this rule, finds a certain level of CWD infection acceptable. On page 35544 of the Federal Register notice, the rule states, “The persistence of CWD in wild cervid populations and our current lack of knowledge about the transmission of CWD have made the goal of eliminating CWD from farmed or captive cervids impractical”. This statement (a) completely ignores the role captive cervid facilities have played in the spread and persistence of CWD, and (b) clearly argues for more restrictive regulations on captive cervid operations and the movement of cervids. It is our opinion that this voluntary herd certification program will not achieve its stated goals.
For the reasons stated by USDA-APHIS in this rule, and the threat CWD poses to the wild cervid sport hunting industry, we feel this rule should be suspended until a more comprehensive and mandatory rule can be put in place. At the very least, we would request and extension of the comment period on this rules since it has gone through three revisions over the past six years and is only now being finalized. Many sportsmen and interested organizations are just now becoming aware of this rule and its potential to impact to wildlife and the ever expanding range of CWD infected captive cervids.
Sincerely,
--
Michael Butler, CEO
Tennessee Wildlife Federation
300 Orlando Avenue, Suite 200
Nashville, TN 37209
TN Wildlife Resources Agency, TN Wildlife Federation and the Rocky Mountain Elk Foundation were all part of this illegal attempt to import elk from Canada and KY that did not meet state and federal regulations. As you can see from Butler's comments, they want a double standard whereby Government Wildlife Agencies can freely move elk with little or no testing but captive raised cervids need to be tested to death according to Butler.
Butler has come to be known as the man that sunk the ship and about 200 elk were lost. Had it not been for the fact that he was bragging on an Internet site about the up-coming risky elk importation, the Coalition would not have known about it in time to prove the elk did not qualify for importation. Loose lips sinks ships.
***************************
http://www.regulations.gov/#!docketDetail;rpp=250;so=ASC;sb=postedDate;po=300;D=APHIS-2006-0118
August 13, 2012
Dr. Patrice Klein
Senior Staff Veterinarian
National Center for Animal Health Programs
Veterinary Services, APHIS
4700 River Road, Unit 43
Riverdale, MD 20737
RE: APHIS-2006-0118
Dear Dr. Klein,
The follow comments are preliminary comments of the Tennessee Wildlife Federation as they relate to the proposed Chronic Wasting Disease Herd Certification Program and Interstate Movement of Farmed or Captive Deer, Elk and Moose. We will follow these comments with more detail comments and information on this and related issues to the proposed rule.
The stated purpose, as we read this revised proposed rule, is to “establish a herd certification program for herd owners and States to control the incidence of CWD in farmed and captive cervids and prevent the interstate spread of CWD”. Keeping this in mind, we do not feel that this proposed rule will successfully meet to USDA-APHIS stated goal. Our specific comments are as follows.
1. This proposed rule appears to largely ignore the realities and threats that captive cervid operations pose to native wild cervids and the tens of billions of dollars of economic impacts that wild cervids provide to rural economies across the United States. While it makes sense that USDA-APHIS would focus upon helping herd owners and States control the incidence of CWD, we ask how USDA-APHIS can achieve its stated goal without a broader coordination with state wildlife agencies and interests and the realization that CWD poses a significant threat to these wild cervid populations.
2. “Herds that do not have any CWD-infected or CWD-exposed animals for 5 years will be granted Certified status” – The 5-year timeframe being applied in this rule appears to be insufficient to prevent the spread of CWD. Currently, there is no known incubation period for CWD and there are examples of cervids which have been infected and did not present symptoms until after they had passed the 5-years age threshold. Thus the 5-year time frame appears insufficient and should be modified to a longer timeframe that reflects the current knowledge of CWD incubation periods.
3. It appears that USDA-APHIS, via the language of this rule, finds a certain level of CWD infection acceptable. On page 35544 of the Federal Register notice, the rule states, “The persistence of CWD in wild cervid populations and our current lack of knowledge about the transmission of CWD have made the goal of eliminating CWD from farmed or captive cervids impractical”. This statement (a) completely ignores the role captive cervid facilities have played in the spread and persistence of CWD, and (b) clearly argues for more restrictive regulations on captive cervid operations and the movement of cervids. It is our opinion that this voluntary herd certification program will not achieve its stated goals.
For the reasons stated by USDA-APHIS in this rule, and the threat CWD poses to the wild cervid sport hunting industry, we feel this rule should be suspended until a more comprehensive and mandatory rule can be put in place. At the very least, we would request and extension of the comment period on this rules since it has gone through three revisions over the past six years and is only now being finalized. Many sportsmen and interested organizations are just now becoming aware of this rule and its potential to impact to wildlife and the ever expanding range of CWD infected captive cervids.
Sincerely,
--
Michael Butler, CEO
Tennessee Wildlife Federation
300 Orlando Avenue, Suite 200
Nashville, TN 37209
