I just got this email and wanted to pass it on....
Recent Updates & Comments to Federal CWD Program Standards
Comments to Federal CWD Program Standards
By Laurie Seale - President of Whitetails of Wisconsin
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I have been asked to respond to the federal CWD program standards and the federal CWD rules because of my years of involvement and knowledge of both documents.*
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Here are the major negative issues associated with the program standards:
Allows USDA and state agencies to quarantine CWD farms (like the Brakke's) for 5 or more years without indemnification. *
Allows USDA and state agencies to quarantine trace back and trace forward farms for 5 or more years without indemnification.*
The program standards has included wording "suggesting" that states allow CWD exposed animals to move to terminal hunting facilities, but without any ability to force states to allow movement, we all know that the large majority of state agencies are not going to allow any exposed animals to move (Brakke case in Iowa a perfect example).*
USDA has not included any wording in the Program standards for indemnification.* This tells me that USDA has no intention of providing indemnification now or in the future leaving the breeders and the states to deal with the disease. *
Program standards state "if any trace back or trace forward animal is no longer available for testing (for example, a trace animal from a known positive herd died and was not tested), the trace back/trace forward herd could be quarantined up to 5 years."* This statement alone forces the cervid industry to test at 100% for fear of a trace back or trace forward.*
In several parts of the standards, farms will be forced into herd plans which can require long quarantine periods, double fencing, expensive clean up, maintaining fencing for up to 5 years even after depopulation, require testing of all mortalities regardless of age, future land use restrictions, etc.; all of this without indemnification.* HOW CAN THE INDUSTRY BUY INTO THE GOVERNMENT TELLING US WHAT TO DO WITH OUR PRIVATE PROPERTY?* If USDA or the states are providing indemnification for our animals with a signed herd plan, then and only then would the government have the right to place restrictions on our private property.
Program standards includes wording that if a producer does not follow a herd plan they could be held responsible for infecting other cervids.....this wording could open the door for lawsuits against producers if CWD is discovered in wild herds.
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There are a number of other serious issues with the program standards, but those listed above are the most intrusive and have the greatest impact on producers.
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The major problem I see with the current program standards document is USDA appears to be holding firm in the process and are writing the standards to be more stringent than the actual federal rule.* A document more stringent than the federal rules is not acceptable.*
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Another major problem is the fact that the federal CWD program is an unfunded federal mandate no longer seen as an eradication program but instead a control program aimed at minimizing risk.* The program standards, on the other hand, are being written solely as an eradication program.* So, if the if* USDA has changed their direction of the program from eradication to a control program, why is USDA not writing the program standards as a control program?* If there was federal or state funding to run the program and USDA was offering indemnification for CWD infected or exposed herds, I don't believe producers would have a problem with an eradication policy.* Again, the program is an unfunded federal mandate and* 5 years of quarantine without indemnification is not acceptable.* Can any producer afford to be quarantined for any length of time?
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We all need to empathize with Tom and Rhonda Brakke and put ourselves in their situation; is the way the Brakke's are being treated by their state government acceptable?* Would any of us be satisfied with 5 years of quarantine without indemnification or without movement of exposed animals to a terminal hunting ranch? The Brakke's own both a breeding herd and a hunting ranch, both of which are CWD exposed facilities. The state of Iowa will not allow them to depopulate their animals by hunting them. I think we all agree that this is not acceptable...not only is this not acceptable but this is America and the taking of one's livelihood and property without compensation is against the law. *
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Legal council has stated that the program standards, as written, will lend a level of credibility to state agencies' actions regarding 5 years quarantine without indemnification.* Legal council also stated this would be especially true if a major cervidae group approved of such standards. This legal advice should tell all of us that we cannot accept this document as currently written!
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Although the program standards working group have made several suggestions for the improvement of this document, these are ONLY suggestions.* Dr. Klein has repeatedly stated she cannot guarantee that these changes will ever be written into the final document because of public comment and we all know what they did to the federal rule after public comment...changes were made to the rule that were detrimental to producers....herein lies the risk to all of us.*
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This document is designed to put producers out of business without compensation for our animals.* The trace backs and trace forwards are designed to shut down interstate movement or at least greatly hinder movement. *
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We all need to think about the consequences of being involved in a trace back, trace forward or an actual CWD on our premises. There are serious consequences...just ask the Brakke's!
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Many of you have heard me say numerous times, if you can't legislate an industry out of business, you regulate them out of business and it is obvious that this is the goal of some of the regulatory agencies.* If the federal CWD rule was really written to prevent the spread of CWD, why would USDA not hold wildlife agencies to the same standards? *
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Laurie Seale
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