To All EWA Members,
We need your help!
Texas Parks and Wildlife Department (TPWD) is set to vote on the newly proposed TTT permit rules at their Commission meeting on March 24 2022, at 9 AM.
How can you help?
  • Submit a public comment! (All comments must be submitted by March 23, at 5PM.)
  • Or join us at the hearing in Austin on March 24, 2022 at TPWD headquarters (4200 Smith School Road).
Why is your help important?
  • TPWD Commissioners need to hear how our industry is unfairly singled out and have unified opposition on record when they hold the final vote on the TTT permit adoption! There’s power in numbers!
Not sure what to say? We’ve compiled a few talking points for you to use!
  • Treating one stakeholder differently than another is unfair. We must trust the statistical confidence provided by prior testing surveillance of deer breeders who are movement qualified and remove the antemortem testing requirement or align testing requirement for all stakeholders prior to movement or release.
  • This proposal encourages TPWD to trust statistical confidence outside of deer pens by requiring the submission of 60 post-mortem test samples on the trap sites intending to utilize the TTT permit. Even though the animal has been trapped and is available for the test prior to movement, it does not require live testing.
  • TPWD and TVMDL should be required to ensure the costs of all samples sent in for CWD surveillance are standardized for everyone. The preamble of this proposal indicates TTT permit holders would pay less for test samples than deer breeders.
  • Our industry is worried about the drastic difference in cost for testing in different stakeholder groups. This furthers our concern that the CWD rules adopted last year were not based on science or containment and were designed to drive deer breeders out of business.
  • The maximum cost for a TTT Permit holder to perform required testing on the movement of 100 deer is $4200 (60 post-mortem tests at $70 per test) under this proposal. The MINIMUM cost for a deer breeder in the movement of 100 deer is $30,000.
  • TPWD Staff is proposing unnecessary and redundant requirements by calling for additional ear tags and authorizing TPWD staff to set or change tag requirements at any time without Commission approval.
  • The deer breeder industry continues to be concerned with TPWD’s approach in imposing harsh and costly measures on breeders while treating all other situations differently.
How do you submit a comment?
  • CLICK HERE to submit public comment.
  • Follow the prompts to enter your name, county and registration status.
  • See the TTT permit provisions/proposal
  • Scroll to the bottom of the page
  • Select “Disagree Completely” and add your comments before hitting submit.
Charly Seale
Executive Director