Federal CWD Rule & Standards-- love it or leave it? You decide!

Federal CWD Rule and Standards-- love it or leave it? You decide!



As we watch our neighbors deal with turmoil regarding cwd policy we have to ask ourselves why are we dealing with this and what do we hope to accomplish?



In regard to the federal rule and specifically the program standards...



What are we gaining by these standards and rule and the overall handling of CWD policy at the federal level?



Do we get an indemnity process? No.



Do we get any relief for our farms to test a lower percentage if they have been in the monitoring program for over a dozen years? No.



Is there any relief for the testing of slaughter animals in any capacity? No.



Does this allow states with like minded policies to work together? No, because states with friendly policies have to meet the federal criteria which is higher than theirs.



Did they take our comments last summer when we were asked by cervid leaders to offer hundreds of comments? No.



Do the standards move toward control instead of eradication? No.



Did they add parity of testing percentages to wildlife agencies? No. We test 100% and they test 2%.



Do they prohibit transporting of cervids without testing by wildlife agencies? No.



Did USDA even want to review these standards? No, the only reason the working group exists is because Charly Seale, Eric Mohlman, and Dr Anderson introduced a resolution at the USAHA conference last October.



We cannot “work backwards” on this rule in hopes of trusting it will get better for the industry. First, why would we trust them? They didn’t take our comments last summer. Second, if the USDA has any intention of working with the industry and state vets they would’ve given us what we wanted in the first place, or even now.



As a lobbyist by profession, I cannot fathom a scenario in which I or any of my colleagues would work to pass legislation detrimental to my client in hopes of amending in the future to lessen damage or impact. This concept is mind-boggling to me. Absolutely blows my mind. I can’t understand it. If I am working on legislation and the process goes awry, or a harmful amendment somehow is adopted at the last minute, I would utilize every option I have to kill the legislation and start over next year. Never would I ever work to allow a bill detrimental to my clients pass into law with the hope to “fix” it next year. Sometimes legislation doesn’t go the way you want, but this isn’t the case. This is the case of the federal rule with the “USDA is giving the industry what it asked for.” NOT.



So looking at the state and federal levels of agencies, your state DNR corresponds with the US Fish and Wildlife. I would assume they view policy the same way. Moreover, the state department of Agriculture corresponds with the USDA. However, in this case we see the USDA teaming up with the DNR, and the state vets (state Dept of Ag) are left saying they can’t comply with the regulations. So who are our friends here? In these standards meetings it’s the state vets and industry vs the USDA and DNR… Why is that? This example goes to the credibility of believing the USDA “will fix” the rule and standards later.



Do we really think we will ever get indemnity? NO! We are in a $17 TRILLION dollar deficit that we wont climb out of for fifty years. Do we really think they are going to avoid national defense and education cuts to fund a CWD program they don’t even care about? Who are we kidding?



Make no mistake, the USDA can suggest control guidelines if they really want to.



The ACA Council members will vote to take action on this early April and deliberate what action to take. As a reminder, each association that participates in the ACA will appoint a councilman from their association to be their voice on the council. Your voice will be heard through through councilman.



Thank you,



Travis Lowe

Kansas Cervid Breeders Assoc

Here background of the federal rule and standards activity as stated in the ACA scope/issues post.



Federal CWD Rule- As everyone is probably aware, the federal CWD rule came out last summer and did very little to help our industry operate financially viable farming operations. The cervid industry waited a decade for the rule and was less than satisfied with the results. There is no longer money for indemnification, no testing relief for farms with over a dozen years of monitoring, no relief for slaughter testing, and a new requirement of mandatory testing of animals over twelve months old instead of the usual sixteen months. There is also a requirement for 100% testing of all harvested animals from trophy ranches that are part of the monitoring program.



The proposed rule was open for public comment for sixty days. The industry rallied over two hundred comments of suggested changes. Very little if any changes recommended by the cervid industry were implemented.



In October 2012, at the United States Animal Health Association (USAHA) Annual Conference the Federal CWD Rule was a topic of major discussion. The North American Elk Breeders Association Executive Director Eric Mohlman, Exotic Wildlife Association Executive Director Charly Seale and Minnesota’s Board of Animal Health official Dr. Paul Anderson offered a resolution that was adopted to create a task force to review and recommend changes to the federal standards before it is permanently implemented. The working group was created that would include three industry seats along with representatives from the USDA, US Fish and Wildlife, and state agriculture officials. The cervid industry representatives on the task force are Eric Mohlman of NAEBA, Charly Seale of EWA and Shawn Schafer of NADeFA. The group was given 90 days to go through the standards and agree on recommendations.



As almost everyone in industry agrees, there are elements in the standards that are unacceptable to the industry and hopefully the USDA will make several changes to create a good business environment for breeders. The product of this working group will be sent to USDA as recommendations and then be subject to further scrutiny and be available for public comments. Unfortunately some breeders are being made to believe that the working groups’ decisions are being implemented as positive changes and accomplishments. We hope there are positive changes made because the standards, as it is now written, are still unacceptable.



The ACA leaders are reviewing the progress to determine if the standards of the federal rule are acceptable to the industry. The industry waited over a decade for this rule and it is essential the standards and the rule reflect the input industry has given along the way but unfortunately most has been ignored to this point. Unless we have a rule and standards that allow free trade and encourage commerce we as an industry shouldn’t be supporting it or its implementation.