Joined Apr 2009
1,130 Posts | 0+
Columbia, MO
Our BOD with help from our lobbyist and our lawyer has written a position statement.
I want to ask the industry's help with posting our "position" on every blog, as comments on every bad article, and as a response to every news story that comes out. Feel free to copy and paste all over the internet. THANKS IN ADVANCE from Missouri Breeders.
'times new roman', serifMISSOURI WHITETAIL BREEDERS AND
'times new roman', serifHUNTING RANCH ASSOCIATION
'times new roman', serifPOSITION STATEMENT
'times new roman', serifI. Executive Summary
margin-left:.5in 'times new roman', serifWhitetail Breeders and Hunting Ranch Operators are small business owners fighting to protect their businesses and a thriving industry in the State of Missouri. Government over-regulation, with no appreciable benefit to the public, is a serious threat to this industry. Whitetail Breeders and Hunting Ranch Operators support efforts to fight chronic wasting disease– it threatens us particularly more than any other business. But we oppose regulations that increase costs and bureaucracy without addressing the real problem at hand. Namely we support the classification of captive Whitetail and other cervids as privately-owned livestock. We oppose any regulation that would increase fencing requirements, including requiring fences higher than the current eight (8) feet or double fencing. We support a requirement that all breeders, other than hunting preserves, test any dead deer for disease. We oppose efforts to stop importation of disease-free deer into the state. We oppose an increase in permit/licensing fees. We support increased enrollment in identification and tracking programs. The remainder of this position statement provides you with background information and a more thorough analysis of these issues.
'times new roman', serifI. Background
'times new roman', serifDuring the last fourteen (14) years, the captive cervid industry has taken many steps to ensure that our captive cervid herds are kept free from all threats of disease. Our industry has been especially diligent during the last three (3) years, since the first positive/suspect Chronic Wasting Disease (hereinafter “CWD�) case was discovered in the State of Missouri. We have worked extensively with the Missouri Department of Agriculture (hereinafter “MDA�) and Missouri Department of Conservation (hereinafter “MDC�) to remove CWD from our captive herds and to ensure that we continue to monitor our herds at an extremely high level in order to prevent future incidence.
'times new roman', serifIt is important to point out that although the origins of the CWD in the infected area are unknown; it is well-established that the disease was discovered by our captive cervid industry because of our effective, systematic monitoring programs. The monitoring programs did what they were designed to do and alerted us to a problem area. Like any disease, early detection is vital in order to minimize the threat posed by CWD and other diseases.
'times new roman', serifIt is also important to note that our captive cervid herds in Missouri are once again CWD free. We will continue to monitor all of our herds for CWD and other diseases such as Tuberculosis and Brucellosis. As a result of these efforts, herds in Missouri are proving to be healthier each year as our programs get stronger.
'times new roman', serifII. Position
margin-left:.5in 'times new roman', serifA. Introduction
margin-left:.5in 'times new roman', serifAs a state-wide alliance between cervid breeders and hunting preserve operators dedicated to conserving nature for future generations, the Missouri Whitetail Breeders and Hunting Ranch Association (MWBHRA) members believe that managed captive herds in our state need to be actively managed and conserved based on sound and proven scientific principles and consistent best management practices. MWBHRA members recognize that white-tailed deer (Odocoileus virginianus) and other species of cervidae (Elk, Red Stag, Sika, Fallow etc.) are an important component of the biodiversity within the state and represent a very significant economic, ecological, and social impact.
margin-left:.5in 'times new roman', serifThe captive cervid industry is one of the most dynamic and fastest growing industries in the country. Compared to traditional livestock operations, the captive cervid industry is experiencing expediential growth. It generates billions of dollars for the U.S. economy and supports tens of thousands of jobs in communities across the country. Valuable game animals, deer 'times new roman', serif not only generate 'times new roman', serifsignificant incomes and value-added products 'times new roman', serifthroughout the 'times new roman', serif private sector, but hunting licenses, 'times new roman', serif enforcement 'times new roman', seriffines and 'times new roman', seriffees provide a great deal of financial support to 'times new roman', serifstate 'times new roman', serifgame agencies. 'times new roman', serifNaturally, along with this consistent industry growth, come ever-increasing state and federal regulations and increasing concerns by government entities. 'times new roman', serifSince the majority of industry regulation is left up to the individual states, a significant amount of variability in the regulations exists from state to state and between state and federal agencies themselves. This lack of consistency in laws and regulations may be a factor affecting future industry growth in the State of Missouri.
margin-left:.5in
margin-left:.5in 'times new roman', serifAs you read through this Position Statement bear in mind that all members of the MWBHRA, both captive cervid breeders and hunting ranch operators alike, share a love of the deer herd in Missouri on BOTH sides of the fence. Accordingly, we will continue to work in conjunction with MDA as well as the MDC to minimize any risks that we determine need addressing and to continually improve on our regulations and monitoring programs.
margin-left:.5in
'times new roman', serifIII. Areas of Concern
'times new roman', serifCurrently, all captive elk are considered livestock and fall under the regulations of the MDA. Captive White-tailed deer and other captive cervid species are considered livestock by MDA and wildlife by MDC. So these animals are regulated by both agencies.
'times new roman', serifWhen the existing captive cervid operations began in the state, by law, it was required that the free ranging cervids of the state be excluded. The same applies to any captive cervid operations that become operational thereon. Only legally purchased captive cervids can be used in these operations. As discussed below, all captive cervids in the State of Missouri come from either private captive cervid operations (either in Missouri or from another state) or were born in captivity. 100% of all expenses associated with these animals are paid by the owners/operators, namely feed, veterinarian care, and any and all required medical testing. Ultimately, when these animals are harvested at a hunting preserve, sales taxes are paid to the state.
'times new roman', serifMWBHRA is actively pursuing the withdrawal of White-tail deer and the other captive cervid species from the purview of MDC and the classification of those species as privately-owned livestock under the regulation of MDA, as with Elk. MDA currently administers all of the captive cervid health programs. To require breeders and hunting ranch operators to answer to two different agencies for their captive herds is at best ambiguous and difficult to follow and at worst a massive waste of resources and unnecessarily duplicative.
'times new roman', serifThe owners of cervid breeding operations and high fenced hunting preserves have a great deal invested in their cervids and constructed fences that protect their investment. There is no conclusive scientific evidence that CWD or any other diseases can be transmitted from farmed cervids through the fence to the native cervid population. Further, several published studies found that an eight (8) foot fence is sufficient to both contain whitetail deer and reduce contact between captive and native cervids. Therefore, the need for any additional fencing requirements (i.e. taller fencing or double fencing) is NOT warranted.
'times new roman', serifThe current MDC fencing requirements are ambiguous and unclear. This makes it difficult for cervid breeders and hunting ranch owners to verify that their properties are sufficiently and properly secured as per the terms and conditions of the Wildlife Code. The language in these areas should be revised and made more specific.
'times new roman', serifA practical and fair disease management program should be implemented that allows for a CWD positive facility to be managed so the owner can recover adequate compensation for his or her cervids. A CWD program that requires depopulation at a CWD positive facility MUST have indemnity funds available for those deer breeders and hunting ranch operators. The current CWD contingency plan must be thoroughly updated to match the current existing medical research and state of knowledge regarding CWD. This is an area that both the current working group and/or the Cervid Health Committee should dedicate substantial effort. Most of the identified stakeholders are represented by those two groups and an updated and finished plan should be generated as soon as possible.
'times new roman', serifThe current MDA CWD regulations require breeding operations to be enrolled in the MDA CWD monitoring program and have a status of (1) year to move within the State of Missouri. We recommend that MDA amend the above regulation to require all captive cervid facilities, other than high fenced hunting preserves to CWD test any cervid 12 months old or older that are harvested or otherwise die, regardless of the cause. Our industry constituents support that change in the regulations and in fact have requested such a change in the regulations.
'times new roman', serifMWBHRA 'times new roman', serif requests a change in the regulations to require all captive cervid owners, other than hunting preserves, to enroll in the existing monitoring program. Currently, MDA has in place an agreement, for operators of high fenced hunting preserves, which requires that the preserve operators agree to CWD testing on 100% of cervids imported into Missouri to their hunting preserve when harvested. All hunting ranches in Missouri that import any deer from out of state have signed this agreement and thus, all deer imported into the hunting ranches from out of state are being tested.
'times new roman', serifThe current MDA CWD regulations require any captive cervid to be enrolled in the MDA CWD monitoring program with a status of (1) year to move within Missouri. A Certificate of Veterinary Inspection or a MDA Cervid Movement Certificate is also required on all captive cervids moving within Missouri and submitted to MDA. All captive cervid facilities are required to keep complete records on all cervids both bought and sold. Hunting preserves are required to keep records of both importation and harvest. These regulations minimize the risk of spreading any disease and also provides, both government agencies and breeders and hunting ranch operators alike, an effective “paper trail� used to track movement of cervids in the event of a disease related incident.
'times new roman', serifAs discussed above, MWBHRA members support requiring all whitetail deer breeders be enrolled in the CWD monitoring program. In addition, MWBHRA requests that after enrollment in the CWD monitoring program, the current one (1) year status requirement be increased to a five (5) year status requirement over a period of the next five (5) years.
'times new roman', serifThe 'times new roman', serifMWBHRA 'times new roman', serif opposes any efforts by MDA or MDC to prohibit importation of cervids into the State of Missouri. The current MDA regulations for the importation of cervids into Missouri adequately protects against diseases entering Missouri. All cervids must be from a five (5) year or more monitored herd. Additional requirements exist for both Tuberculosis and Brucellosis and all imported animals must be accompanied by a certificate of Health clearly showing the permit number issued by the MDA. There is no evidence of any diseases being introduced into Missouri from the transportation of farmed cervids. So to prohibit importation is not warranted.
'times new roman', serifThere is no conclusive medical evidence that live animal auction facilities have caused or otherwise aided in the movement of diseased cervids. All cervids selling through an auction facility must meet MDA health and testing requirements in order to be sold at the auction. The MDA has worked extensively with these facilities to ensure that holding areas are properly constructed and maintained and that all animals entering these facilities have the proper documentation, including the proper permits and health certificates. As discussed above, any and all cervids entering these facilities are required to be properly monitored for CWD. To prohibit cervids in live animal auctions is not warranted.
'times new roman', serifMWBHRA 'times new roman', serif opposes any proposed increases in permit fees by MDC for either deer breeders or hunting ranch operators. No increase in such permit fees is warranted as MDC revenue is sufficiently generated through sales tax accumulated on sales at the hunting preserves. Further, breeders and hunting ranch operators bear 100% of administration of the testing for the CWD monitoring program through testing fees, permits, licenses etc... no need for additional fees/taxes etc. 'times new roman', serif 11pt[1]
'times new roman', serifOur goal as an industry is to be able to identify and track all captive cervids within the State of Missouri. MDA requires all captive cervid facilities to maintain complete records that include official animal I.D., date of birth, gender, date and source of acquisition, date of removal, and destination of any animal removed, date died, and CWD test result, if applicable. Our industry has recommended that all captive cervids other than hunting preserves must be enrolled in our monitoring program. 'times new roman', serif 11pt[2] That means that each year these inventories must be reconciled to remain in and advance in the program. This will ensure that all captive cervids and their movement will be recorded. Our industry supports an open data base that can be shared by all agencies involved.
11pt[1] 'times new roman', serif 9ptThe traditional method in testing for presence of CWD is a post-mortem test, using the extracted brain 'times new roman', serif 9ptstem (obex) and retropharyngeal lymph nodes. 'times new roman', serif 9pt Breeders and hunting ranch operators bear 100% of the expense for testing each and every cervid that is harvested or otherwise dies, regardless of cause. This represents a substantial financial burden.
9pt 9pt[2] 'times new roman', serif 9ptHunting preserve operators already operate under a similar recordation program, regulated by the MDC, requiring them to “keep a permanent record, by date, of the number of each species held, acquired, propagated, sold, released, the number of each species taken on the premises and the full name, address, and permit number (if applicable) of each buyer, seller, shooter, and/or taker, on forms provided by the department.â€� 3 CSR §10-9.566 Licensed Hunting Preserve; Records Required.
I want to ask the industry's help with posting our "position" on every blog, as comments on every bad article, and as a response to every news story that comes out. Feel free to copy and paste all over the internet. THANKS IN ADVANCE from Missouri Breeders.
'times new roman', serifMISSOURI WHITETAIL BREEDERS AND
'times new roman', serifHUNTING RANCH ASSOCIATION
'times new roman', serifPOSITION STATEMENT
'times new roman', serifI. Executive Summary
margin-left:.5in 'times new roman', serifWhitetail Breeders and Hunting Ranch Operators are small business owners fighting to protect their businesses and a thriving industry in the State of Missouri. Government over-regulation, with no appreciable benefit to the public, is a serious threat to this industry. Whitetail Breeders and Hunting Ranch Operators support efforts to fight chronic wasting disease– it threatens us particularly more than any other business. But we oppose regulations that increase costs and bureaucracy without addressing the real problem at hand. Namely we support the classification of captive Whitetail and other cervids as privately-owned livestock. We oppose any regulation that would increase fencing requirements, including requiring fences higher than the current eight (8) feet or double fencing. We support a requirement that all breeders, other than hunting preserves, test any dead deer for disease. We oppose efforts to stop importation of disease-free deer into the state. We oppose an increase in permit/licensing fees. We support increased enrollment in identification and tracking programs. The remainder of this position statement provides you with background information and a more thorough analysis of these issues.
'times new roman', serifI. Background
'times new roman', serifDuring the last fourteen (14) years, the captive cervid industry has taken many steps to ensure that our captive cervid herds are kept free from all threats of disease. Our industry has been especially diligent during the last three (3) years, since the first positive/suspect Chronic Wasting Disease (hereinafter “CWD�) case was discovered in the State of Missouri. We have worked extensively with the Missouri Department of Agriculture (hereinafter “MDA�) and Missouri Department of Conservation (hereinafter “MDC�) to remove CWD from our captive herds and to ensure that we continue to monitor our herds at an extremely high level in order to prevent future incidence.
'times new roman', serifIt is important to point out that although the origins of the CWD in the infected area are unknown; it is well-established that the disease was discovered by our captive cervid industry because of our effective, systematic monitoring programs. The monitoring programs did what they were designed to do and alerted us to a problem area. Like any disease, early detection is vital in order to minimize the threat posed by CWD and other diseases.
'times new roman', serifIt is also important to note that our captive cervid herds in Missouri are once again CWD free. We will continue to monitor all of our herds for CWD and other diseases such as Tuberculosis and Brucellosis. As a result of these efforts, herds in Missouri are proving to be healthier each year as our programs get stronger.
'times new roman', serifII. Position
margin-left:.5in 'times new roman', serifA. Introduction
margin-left:.5in 'times new roman', serifAs a state-wide alliance between cervid breeders and hunting preserve operators dedicated to conserving nature for future generations, the Missouri Whitetail Breeders and Hunting Ranch Association (MWBHRA) members believe that managed captive herds in our state need to be actively managed and conserved based on sound and proven scientific principles and consistent best management practices. MWBHRA members recognize that white-tailed deer (Odocoileus virginianus) and other species of cervidae (Elk, Red Stag, Sika, Fallow etc.) are an important component of the biodiversity within the state and represent a very significant economic, ecological, and social impact.
margin-left:.5in 'times new roman', serifThe captive cervid industry is one of the most dynamic and fastest growing industries in the country. Compared to traditional livestock operations, the captive cervid industry is experiencing expediential growth. It generates billions of dollars for the U.S. economy and supports tens of thousands of jobs in communities across the country. Valuable game animals, deer 'times new roman', serif not only generate 'times new roman', serifsignificant incomes and value-added products 'times new roman', serifthroughout the 'times new roman', serif private sector, but hunting licenses, 'times new roman', serif enforcement 'times new roman', seriffines and 'times new roman', seriffees provide a great deal of financial support to 'times new roman', serifstate 'times new roman', serifgame agencies. 'times new roman', serifNaturally, along with this consistent industry growth, come ever-increasing state and federal regulations and increasing concerns by government entities. 'times new roman', serifSince the majority of industry regulation is left up to the individual states, a significant amount of variability in the regulations exists from state to state and between state and federal agencies themselves. This lack of consistency in laws and regulations may be a factor affecting future industry growth in the State of Missouri.
margin-left:.5in
margin-left:.5in 'times new roman', serifAs you read through this Position Statement bear in mind that all members of the MWBHRA, both captive cervid breeders and hunting ranch operators alike, share a love of the deer herd in Missouri on BOTH sides of the fence. Accordingly, we will continue to work in conjunction with MDA as well as the MDC to minimize any risks that we determine need addressing and to continually improve on our regulations and monitoring programs.
margin-left:.5in
'times new roman', serifIII. Areas of Concern
- 'times new roman', serifWhite-tail deer and other captive cervids should be private livestock under MDA regulation
'times new roman', serifCurrently, all captive elk are considered livestock and fall under the regulations of the MDA. Captive White-tailed deer and other captive cervid species are considered livestock by MDA and wildlife by MDC. So these animals are regulated by both agencies.
'times new roman', serifWhen the existing captive cervid operations began in the state, by law, it was required that the free ranging cervids of the state be excluded. The same applies to any captive cervid operations that become operational thereon. Only legally purchased captive cervids can be used in these operations. As discussed below, all captive cervids in the State of Missouri come from either private captive cervid operations (either in Missouri or from another state) or were born in captivity. 100% of all expenses associated with these animals are paid by the owners/operators, namely feed, veterinarian care, and any and all required medical testing. Ultimately, when these animals are harvested at a hunting preserve, sales taxes are paid to the state.
'times new roman', serifMWBHRA is actively pursuing the withdrawal of White-tail deer and the other captive cervid species from the purview of MDC and the classification of those species as privately-owned livestock under the regulation of MDA, as with Elk. MDA currently administers all of the captive cervid health programs. To require breeders and hunting ranch operators to answer to two different agencies for their captive herds is at best ambiguous and difficult to follow and at worst a massive waste of resources and unnecessarily duplicative.
- 'times new roman', serifSecure separation of captive and free-ranging cervids-fencing.
'times new roman', serifThe owners of cervid breeding operations and high fenced hunting preserves have a great deal invested in their cervids and constructed fences that protect their investment. There is no conclusive scientific evidence that CWD or any other diseases can be transmitted from farmed cervids through the fence to the native cervid population. Further, several published studies found that an eight (8) foot fence is sufficient to both contain whitetail deer and reduce contact between captive and native cervids. Therefore, the need for any additional fencing requirements (i.e. taller fencing or double fencing) is NOT warranted.
'times new roman', serifThe current MDC fencing requirements are ambiguous and unclear. This makes it difficult for cervid breeders and hunting ranch owners to verify that their properties are sufficiently and properly secured as per the terms and conditions of the Wildlife Code. The language in these areas should be revised and made more specific.
- 'times new roman', serifDisease clean up and support.
'times new roman', serifA practical and fair disease management program should be implemented that allows for a CWD positive facility to be managed so the owner can recover adequate compensation for his or her cervids. A CWD program that requires depopulation at a CWD positive facility MUST have indemnity funds available for those deer breeders and hunting ranch operators. The current CWD contingency plan must be thoroughly updated to match the current existing medical research and state of knowledge regarding CWD. This is an area that both the current working group and/or the Cervid Health Committee should dedicate substantial effort. Most of the identified stakeholders are represented by those two groups and an updated and finished plan should be generated as soon as possible.
- 'times new roman', serifCaptive cervid testing – herd certification
'times new roman', serifThe current MDA CWD regulations require breeding operations to be enrolled in the MDA CWD monitoring program and have a status of (1) year to move within the State of Missouri. We recommend that MDA amend the above regulation to require all captive cervid facilities, other than high fenced hunting preserves to CWD test any cervid 12 months old or older that are harvested or otherwise die, regardless of the cause. Our industry constituents support that change in the regulations and in fact have requested such a change in the regulations.
'times new roman', serifMWBHRA 'times new roman', serif requests a change in the regulations to require all captive cervid owners, other than hunting preserves, to enroll in the existing monitoring program. Currently, MDA has in place an agreement, for operators of high fenced hunting preserves, which requires that the preserve operators agree to CWD testing on 100% of cervids imported into Missouri to their hunting preserve when harvested. All hunting ranches in Missouri that import any deer from out of state have signed this agreement and thus, all deer imported into the hunting ranches from out of state are being tested.
- 'times new roman', serifCaptive cervid movement – intrastate.
'times new roman', serifThe current MDA CWD regulations require any captive cervid to be enrolled in the MDA CWD monitoring program with a status of (1) year to move within Missouri. A Certificate of Veterinary Inspection or a MDA Cervid Movement Certificate is also required on all captive cervids moving within Missouri and submitted to MDA. All captive cervid facilities are required to keep complete records on all cervids both bought and sold. Hunting preserves are required to keep records of both importation and harvest. These regulations minimize the risk of spreading any disease and also provides, both government agencies and breeders and hunting ranch operators alike, an effective “paper trail� used to track movement of cervids in the event of a disease related incident.
'times new roman', serifAs discussed above, MWBHRA members support requiring all whitetail deer breeders be enrolled in the CWD monitoring program. In addition, MWBHRA requests that after enrollment in the CWD monitoring program, the current one (1) year status requirement be increased to a five (5) year status requirement over a period of the next five (5) years.
- 'times new roman', serifCaptive cervid movement – interstate.
'times new roman', serifThe 'times new roman', serifMWBHRA 'times new roman', serif opposes any efforts by MDA or MDC to prohibit importation of cervids into the State of Missouri. The current MDA regulations for the importation of cervids into Missouri adequately protects against diseases entering Missouri. All cervids must be from a five (5) year or more monitored herd. Additional requirements exist for both Tuberculosis and Brucellosis and all imported animals must be accompanied by a certificate of Health clearly showing the permit number issued by the MDA. There is no evidence of any diseases being introduced into Missouri from the transportation of farmed cervids. So to prohibit importation is not warranted.
- 'times new roman', serifDirect and indirect live animal interactions – exhibits, auctions, and sale facilities.
'times new roman', serifThere is no conclusive medical evidence that live animal auction facilities have caused or otherwise aided in the movement of diseased cervids. All cervids selling through an auction facility must meet MDA health and testing requirements in order to be sold at the auction. The MDA has worked extensively with these facilities to ensure that holding areas are properly constructed and maintained and that all animals entering these facilities have the proper documentation, including the proper permits and health certificates. As discussed above, any and all cervids entering these facilities are required to be properly monitored for CWD. To prohibit cervids in live animal auctions is not warranted.
- 'times new roman', serifPermitting – fees
'times new roman', serifMWBHRA 'times new roman', serif opposes any proposed increases in permit fees by MDC for either deer breeders or hunting ranch operators. No increase in such permit fees is warranted as MDC revenue is sufficiently generated through sales tax accumulated on sales at the hunting preserves. Further, breeders and hunting ranch operators bear 100% of administration of the testing for the CWD monitoring program through testing fees, permits, licenses etc... no need for additional fees/taxes etc. 'times new roman', serif 11pt[1]
- 'times new roman', serifSystem of Inventory Control
'times new roman', serifOur goal as an industry is to be able to identify and track all captive cervids within the State of Missouri. MDA requires all captive cervid facilities to maintain complete records that include official animal I.D., date of birth, gender, date and source of acquisition, date of removal, and destination of any animal removed, date died, and CWD test result, if applicable. Our industry has recommended that all captive cervids other than hunting preserves must be enrolled in our monitoring program. 'times new roman', serif 11pt[2] That means that each year these inventories must be reconciled to remain in and advance in the program. This will ensure that all captive cervids and their movement will be recorded. Our industry supports an open data base that can be shared by all agencies involved.
11pt[1] 'times new roman', serif 9ptThe traditional method in testing for presence of CWD is a post-mortem test, using the extracted brain 'times new roman', serif 9ptstem (obex) and retropharyngeal lymph nodes. 'times new roman', serif 9pt Breeders and hunting ranch operators bear 100% of the expense for testing each and every cervid that is harvested or otherwise dies, regardless of cause. This represents a substantial financial burden.
9pt 9pt[2] 'times new roman', serif 9ptHunting preserve operators already operate under a similar recordation program, regulated by the MDC, requiring them to “keep a permanent record, by date, of the number of each species held, acquired, propagated, sold, released, the number of each species taken on the premises and the full name, address, and permit number (if applicable) of each buyer, seller, shooter, and/or taker, on forms provided by the department.â€� 3 CSR §10-9.566 Licensed Hunting Preserve; Records Required.
