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Docket No. 00-108-10 Deer Comm, SETWS CWD TSE PRION comment submission March 12 2014
12 March 2013 Docket No. 00-108-10 Regulatory Analysis and Development PPD, APHIS Station 3A-03.8 4700 River Road Unit 118 Riverdale, MD 20737-1238
Dear Sir/Madam:
The Deer Committee, Southeast Section of The Wildlife Society represents wildlife biologists within the southeastern states, in addition to Maryland, Delaware, Missouri and Texas. This committee does not support implementation of the Program Standards as written because they will not minimize the rate of Chronic Wasting Disease (CWD).
We have particular concern over the suggestion that states consider allowing movement of animals that are CWD-positive, CWD-suspect, or CWD–exposed from infected facilities for any reason, including to “shooter pens.” Additionally, allowing the introduction of additional animals into CWD-positive, CWD-suspect and CWD-exposed herds would increase the number of potentially infected animals on the landscape and thus increase the risk of spread. Of greatest concern is allowing movement of live animals from CWD-positive, CWD-suspect and CWD-exposed herds through other states, especially those which do not allow cervid farming and those that are currently CWD negative. Such recommendations are in direct conflict with APHIS’s stated goal of minimizing the risk of spreading CWD.
The Standards note in (4) Fencing that double-fencing might be desirable even though double fencing is not intend “as a comprehensive program standard”. We appreciate this nod to the reality that nose-to-nose contact occurs and increases the risk of spread. In that same spirit, the Standards should recommend only using semen from males in 5-yr certified herds until the true risk from semen and artificial/assisted reproduction can be assessed. Every tissue and body fluid examined for the presence of infectious prions has proven to have them (muscle, blood, urine, and saliva), so efforts to control CWD should assume all tissues and fluids pose similar risk, including semen and eggs. Furthermore, research has demonstrated that similar diseases (scrapie and bovine TSE) can be transmitted via semen and/or artificial insemination procedures (Rubenstein et al. 2012 Journal of General Virology; Wrathall et al. 2008 Theriogenology), Though not required by the Rule, the Standards should recommend that escape of captive deer into the wild and ingress of wild deer into a fenced facility should be reported to the State wildlife agency regardless of jurisdictional involvement with farmed cervids. The State wildlife agency has jurisdiction over any wild deer that get into a facility, and would have to deal with unrecovered escapes
Docket No. 00-108-10 Deer Comm, SETWS
continued
commingling with wild cervids. Furthermore, the State wildlife agency has resources and abilities to address both situations, in contrast to State agriculture/animal health agencies.
Given that the Standards are intended to provide “optional guidelines on best management practices… to manage CWD-affected herds”, the Standards should strongly recommend all clinical CWD suspects be tested regardless of age. Given that the Program Standards are optional, they should include all alternatives that would minimize the risk of disease dissemination. As written these standards do more to insure “continuity of business” for the captive cervid industry than they do for controlling the current serious disease problem. The supposed potential economic value of the captive cervid industry is dwarfed by the $18.1 billion of economic impact (National Shooting Sports Foundation. 2013 Hunting’s Economic Impact) related to our wild deer resource.
The Deer Committee of the Southeast Section of The Wildlife Society most strongly requests that these Program Standards be rejected as written and that revised standards include language that will insure minimizing the dangers posed to our wild deer populations across the United States.
Sincerely,
Steve Demarais, Chair Deer Committee, SE
http://www.regulations.gov/#!documentDetail;D=APHIS-2006-0118-0412
Singeltary submission ;
Program Standards: Chronic Wasting Disease Herd Certification Program and Interstate Movement of Farmed or Captive Deer, Elk, and Moose
*** DOCUMENT ID: APHIS-2006-0118-0411
http://www.regulations.gov/#!documentDetail;D=APHIS-2006-0118-0411
http://chronic-wasting-disease.blogspot.com/2014/03/docket-no-00-108-10-chronic-wasting.html
CommentsView All (398) No comments posted.
Reject the proposed rules. They increase the risk of CWD, facilitate perpetuation of CWD in captive-cervid herds and the environment, and increase the risk of...”
View Comment
Submitter Name: Caywood, JohnPosted: 03/17/2014ID: APHIS-2006-0118-0413
See attached file(s)”
View Comment
Submitter Name: Demarais, StephenPosted: 03/17/2014ID: APHIS-2006-0118-0412
Docket No. 00-108-10 Chronic Wasting Disease Herd Certification Program and Interstate Movement of Farmed or Captive Deer, Elk, and Moose; Program Standards...”
View Comment
Submitter Name: Singeltary, TerryPosted: 03/11/2014ID: APHIS-2006-0118-0411
All deer and elk farms should be ban and made illegal throughout the U.S. Deer and elf farms are the sole reason CWD is so ramped throughout this country. Get...”
View Comment
Submitter Name: Gregory, JamesPosted: 03/10/2014ID: APHIS-2006-0118-0410
The Wisconsin Department of Natural Resources (WI-DNR) has taken this so called Chronic Wasting Disease (CWD) and turned it into one big circus. CWD has been...”
View Comment
Submitter Name: Wurz, GregPosted: 03/10/2014ID: APHIS-2006-0118-0409
http://www.regulations.gov/#!docketDetail;D=APHIS-2006-0118
snip...see full text ;
Tuesday, March 18, 2014
Docket No. 00-108-10 Deer Comm, SETWS CWD TSE PRION comment submission March 12 2014
http://chronic-wasting-disease.blogspot.com/2014/03/docket-no-00-108-10-deer-comm-setws-cwd.html
kind regards,
terry
12 March 2013 Docket No. 00-108-10 Regulatory Analysis and Development PPD, APHIS Station 3A-03.8 4700 River Road Unit 118 Riverdale, MD 20737-1238
Dear Sir/Madam:
The Deer Committee, Southeast Section of The Wildlife Society represents wildlife biologists within the southeastern states, in addition to Maryland, Delaware, Missouri and Texas. This committee does not support implementation of the Program Standards as written because they will not minimize the rate of Chronic Wasting Disease (CWD).
We have particular concern over the suggestion that states consider allowing movement of animals that are CWD-positive, CWD-suspect, or CWD–exposed from infected facilities for any reason, including to “shooter pens.” Additionally, allowing the introduction of additional animals into CWD-positive, CWD-suspect and CWD-exposed herds would increase the number of potentially infected animals on the landscape and thus increase the risk of spread. Of greatest concern is allowing movement of live animals from CWD-positive, CWD-suspect and CWD-exposed herds through other states, especially those which do not allow cervid farming and those that are currently CWD negative. Such recommendations are in direct conflict with APHIS’s stated goal of minimizing the risk of spreading CWD.
The Standards note in (4) Fencing that double-fencing might be desirable even though double fencing is not intend “as a comprehensive program standard”. We appreciate this nod to the reality that nose-to-nose contact occurs and increases the risk of spread. In that same spirit, the Standards should recommend only using semen from males in 5-yr certified herds until the true risk from semen and artificial/assisted reproduction can be assessed. Every tissue and body fluid examined for the presence of infectious prions has proven to have them (muscle, blood, urine, and saliva), so efforts to control CWD should assume all tissues and fluids pose similar risk, including semen and eggs. Furthermore, research has demonstrated that similar diseases (scrapie and bovine TSE) can be transmitted via semen and/or artificial insemination procedures (Rubenstein et al. 2012 Journal of General Virology; Wrathall et al. 2008 Theriogenology), Though not required by the Rule, the Standards should recommend that escape of captive deer into the wild and ingress of wild deer into a fenced facility should be reported to the State wildlife agency regardless of jurisdictional involvement with farmed cervids. The State wildlife agency has jurisdiction over any wild deer that get into a facility, and would have to deal with unrecovered escapes
Docket No. 00-108-10 Deer Comm, SETWS
continued
commingling with wild cervids. Furthermore, the State wildlife agency has resources and abilities to address both situations, in contrast to State agriculture/animal health agencies.
Given that the Standards are intended to provide “optional guidelines on best management practices… to manage CWD-affected herds”, the Standards should strongly recommend all clinical CWD suspects be tested regardless of age. Given that the Program Standards are optional, they should include all alternatives that would minimize the risk of disease dissemination. As written these standards do more to insure “continuity of business” for the captive cervid industry than they do for controlling the current serious disease problem. The supposed potential economic value of the captive cervid industry is dwarfed by the $18.1 billion of economic impact (National Shooting Sports Foundation. 2013 Hunting’s Economic Impact) related to our wild deer resource.
The Deer Committee of the Southeast Section of The Wildlife Society most strongly requests that these Program Standards be rejected as written and that revised standards include language that will insure minimizing the dangers posed to our wild deer populations across the United States.
Sincerely,
Steve Demarais, Chair Deer Committee, SE
http://www.regulations.gov/#!documentDetail;D=APHIS-2006-0118-0412
Singeltary submission ;
Program Standards: Chronic Wasting Disease Herd Certification Program and Interstate Movement of Farmed or Captive Deer, Elk, and Moose
*** DOCUMENT ID: APHIS-2006-0118-0411
http://www.regulations.gov/#!documentDetail;D=APHIS-2006-0118-0411
http://chronic-wasting-disease.blogspot.com/2014/03/docket-no-00-108-10-chronic-wasting.html
CommentsView All (398) No comments posted.
Reject the proposed rules. They increase the risk of CWD, facilitate perpetuation of CWD in captive-cervid herds and the environment, and increase the risk of...”
View Comment
Submitter Name: Caywood, JohnPosted: 03/17/2014ID: APHIS-2006-0118-0413
See attached file(s)”
View Comment
Submitter Name: Demarais, StephenPosted: 03/17/2014ID: APHIS-2006-0118-0412
Docket No. 00-108-10 Chronic Wasting Disease Herd Certification Program and Interstate Movement of Farmed or Captive Deer, Elk, and Moose; Program Standards...”
View Comment
Submitter Name: Singeltary, TerryPosted: 03/11/2014ID: APHIS-2006-0118-0411
All deer and elk farms should be ban and made illegal throughout the U.S. Deer and elf farms are the sole reason CWD is so ramped throughout this country. Get...”
View Comment
Submitter Name: Gregory, JamesPosted: 03/10/2014ID: APHIS-2006-0118-0410
The Wisconsin Department of Natural Resources (WI-DNR) has taken this so called Chronic Wasting Disease (CWD) and turned it into one big circus. CWD has been...”
View Comment
Submitter Name: Wurz, GregPosted: 03/10/2014ID: APHIS-2006-0118-0409
http://www.regulations.gov/#!docketDetail;D=APHIS-2006-0118
snip...see full text ;
Tuesday, March 18, 2014
Docket No. 00-108-10 Deer Comm, SETWS CWD TSE PRION comment submission March 12 2014
http://chronic-wasting-disease.blogspot.com/2014/03/docket-no-00-108-10-deer-comm-setws-cwd.html
kind regards,
terry