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Message Title: URGENT
Author: Autry  Posted: 01\03\2007 19:54
Location: TN
Message:
I just submitted another comment and noticed that the state wildlife agencies are still submitting comments that will have a negative affect on the cervid industry.

Below is my last comment.

It is very obvious that the flood of last minute comments, made by so many state wildlife agencies, is a desperate attempt to negatively affect the cervid industry by pushing for unreasonable rules and regulations for importation in regard to CWD, TB and other diseases. While these state wildlife agencies do not hesitate to promote these unreasonable rules and regulations for the captive cervid industry, these same state wildlife agencies are unwilling to abide by the same rules and regulations. State wildlife agencies are strongly against Federal rules and regulations that would preempt state rules and regulations for several reasons, individual states would not be able to issue a wavier to allow state wildlife agencies to import high risk elk or deer that do not meet the importation requirements in regard to disease issues, individual states would not be able to impose unreasonable rules and regulations, in regard to disease issues, on the captive cervid industry within their state and individual states wildlife agencies would lose control of the monopoly that they have so enjoyed over most of the past century. If these Federal CWD rules, preempting state rules, had been accepted last fall as was planned, the Tennessee Department of Agriculture would not have been able to issue a wavier to the Tennessee Wildlife Resources Agency which allows them to import elk from Elk Island in Alberta Canada without having to meet all of the import requirements. This elk herd, does not meet Tennessee CWD or TB requirements plus CWD has been diagnosed in at least two wild mule deer about 100 miles from the Elk Island herd. It makes no sense to allow state wildlife agencies to decide disease issues for the captive cervid industry when it is so painfully clear that their main objective is not to prevent the spread of disease but to eliminate their competition.

A Wyoming state official, with his implied threat, wants to remain in charge of the rules and regulations in regard to disease issues in his state and this is supported by the Wyoming state wildlife agency. They resent a Federal rule that would preempt state rules. They admit, in their comments, that their state rules and regulations were designed to not only discourage but to eliminate the captive cervid industry within their state. In the state of Wyoming, there is only one privately owned cervid enclosure which was grand fathered in decades ago. Wyoming has more disease problems in their wildlife than any other state with their wildlife having TB, Brucellosis, and CWD and they certainly can not blame the cervid industry. TB, Brucellosis, and CWD have run rampant for decades in Wyoming's wildlife and the Wyoming state officials have done little or nothing to solve the problem and yet they want to influence Federal rules involving disease issues in the captive cervid industry. If the USDA is in need of advise, in regard to disease issues, it should come from someone that has a proven track record of solving diseases issues and not just a record of living with and harboring diseases.

Another state wildlife agency has suggested, in their comments, that all captive cervid herds should be double fenced to protect the wildlife from disease when in reality if double fencing is needed, it is because the captive herds need protection from the wildlife as that is where the greatest risk of disease remains. In this case, the state wildlife agencies should be responsible for the cost of construction and the cost of maintaining the double fences.

The USDA is the Federal agency charged with the responsibility of safeguarding livestock and wildlife in regard to disease issues and the USDA should stand strong and not allow state officials or state wildlife agencies to unnecessarily negatively affect the cervid industry and for that reason, a Federal rule preempting state rules is needed. State wildlife agencies must be held to the same import requirements as the captive cervid industry if the USDA is serious about stopping the spread of disease and this should apply to both live cervids as well as cervid carcasses. The USDA needs to implement reasonable rules that apply to all and it needs to be done ASAP.

David L. Autry
TN Elk Farmers
TN Alternative Livestock Producers