The Exotic Wildlife Association appreciates the opportunity to submit verbal and written comments for the CWD Program Standards. Since 1967, the Exotic Wildlife Association (EWA) has served as the trade association for the breeders of rare and endangered exotic hoofstock, CWD susceptible CWD species such as whitetail deer, elk, red deer, and sika. The EWA Board of Directors has adopted the following declaration and comments as observations and constructive recommendations during the APHIS CWD Listening Sessions taking place in July, August, and September 2023. In the decade since the publication of the federal Chronic Wasting Disease rule and its accompanying Program Standards, those breeders enrolled in the USDA/APHIS herd certification program across the United States, represented by the Exotic Wildlife Association, recommend a re-evaluation of Chronic Wasting Disease strategy as it pertains to the elk, red deer, sika, and whitetail industries.

Current Observations

The EWA has observed a high variance in how the program is administered by participating states, undermining the program’s goal of a consistent approach. USDA/APHIS data demonstrates Chronic Wasting Disease infection among total enrolled cervid herds is a fraction of one percent. However, the enrolled herd owners cite the program requirements and state response as the greatest threat to their animals and barrier to industry growth. Misdirected attention on farmed cervid herds does not address the growing threat of free ranging deer across the landscape. Special interest groups and many state agencies seek to add more requirements to the farmed cervid industry, or halt its existence completely,
while failing to address the greatest vector of Chronic Wasting Disease spread. If cervid farming ceased to exist tomorrow, Chronic Wasting Disease would continue to spread as wildlife stakeholders have not addressed the following:

• Chronic Wasting Disease exists in the wild nearly coast to coast across the United States.
• No state agency has successfully eradicated Chronic Wasting Disease from its free ranging herd.
• There are no safeguards that prevent wild deer migration from endemic states, or counties within a state, into non-endemic territory. To: USDA APHIS From: the Exotic Wildlife Association Re: Requested Changes to CWD Program Standards Overall Direction of the CWD Program Docket No. APHIS-2023-0042
Date: July 27, 2023
• States that discover Chronic Wasting Disease in the wild for the first time later learn it has existed at a high prevalence for years while undetected, demonstrates free-ranging surveillance programs are not sufficient to learn where the disease exists.
• Chronic Wasting Disease exists in the wild in states that do not have a farmed cervid industry.
• The free-ranging herd’s contamination of the environment, subject to possible movement of prions, is largely undocumented and unregulated. Most farmed cervid owners convey they do not believe existing methods of program management are sustainable. EWA reminds stakeholders that the federal rule itself is written with a stated goal of disease control, rather than eradication, as stated by APHIS in the Federal Register on June 13, 2012. The industry commonly notes the language in the federal rule located in the
CFR is “livable”, however many of the Program Standards recommendations include eradication tactics. NAEBA notes many regulators use eradication program tactics for program management and response plans as they would for the TB eradication program, not shiting to a control strategy. Meanwhile, state administrators interpret rules and program guidance differently, providing drastic differences in the program’s application from state to state. States, even counties within, powered by special interest groups, seek to add more stringent requirements more than the federal rule, with USDA unable to
impede such requirements. Given the extremely low disease infection in farmed cervids such as elk and red deer herds, in correlation to escalating draconian requirements employed by states, EWA believes there should be a better way to prevent Chronic Wasting Disease in farmed herds without destroying the industry. If the USDA wants to cultivate an environment for industry to succeed, the program administration defaults must be addressed. EWA recommendations share the goal with all stakeholders to minimize the threat and spread of Chronic Wasting Disease. EWA recommends comprehensive changes to the administration of the program guided by science and lessons learned over the recent

EWA also recommends the USDA Program Standards document should be completely re-written to reflect the following:

(1) Control Guidance. Program guidance should reflect the program’s intent of control methods, not eradication. This is stated in the Federal Register, page 35542, published June 13, 2012, with the agency stating “We have now concluded, however, that our CWD objective should be to establish a herd certification program for herd owners and States to control the incidence of CWD in farmed and captive cervids and prevent the interstate spread of CWD. We have concluded that elimination of CWD from farmed and captive cervids is not practical given the persistence of CWD in wild cervid populations and our current lack of knowledge about how CWD may be transmitted between wild cervid populations and farmed cervids.
(2) State Authority. Given the federal rule’s allowance for states to develop their own rules that can be more stringent, this power should not be implied and is unnecessary in the USDA Program Standards. To promote this is draconian and should not an options for state regulations to be in access of the minimum standards.
(3) Reinforcement of Program Definitions. Investigation of exposed animals should not be extended beyond the definition of CWD exposed animals. A large percentage of state administrators are ordering the or quarantine of animals that do not meet the definition of a CWD exposed animal, CWD exposed herd or CWD suspect animal.
(4) Management of CWD Positive Herds. Guidance should include options with empowerment for states managing CWD positive herds. Given wildlife agency’s inability to prevent the spread within free ranging herds, there should be practical options for herds that discover the disease without the complete loss of their livelihood.
(5) Utilization of Antemortem testing. Utilization of options for antemortem testing for farmed susceptible species as a risk assessment screening tool to prevent unnecessary destruction of animals, lessen time in quarantines and open commerce to closed markets.
(6) Scientific Approach for Quarantine Length. Quarantine should not be a standard 60 month as this length is not known to be derived by science. It is merely an estimate.
(7) Consideration of CWD Genetics. Science shows CWD genotype genetics impact susceptibility and incubation. There is sufficient science to alter program response instead of a one size fits all approach.
(8) Consideration of Species. Science shows species have different susceptibility levels, infection rates and incubation. There is sufficient science to alter program response instead of a one size fits all.
(9) Consideration of Environmental Concerns. The program already uses environmental factors in determining prioritization for indemnity. A similar approach should be used with program response. Should discovery response be the same for herds in Alaska as they are in Wisconsin?
(10)Reality of Reduced and Option Unavailable USDA Indemnity. Given the reduced indemnity values offered by USDA, combined with option unavailable funds to be paid by USDA for depopulation orders of the Program administration, there should be more options to avoid destruction orders.
(11)Practical Replacement Options for Missing or Poor Quality Samples. Current guidance
recommendations draconian response for missing samples, including killing a healthy animal toreplace a missing CWD sample. Program guidance should empower administration to provide exceptions for isolated incidents with the possible utilization of antemortem testing if requested by the herd owner. Killing healthy animals to replace a missed sample should not be allowed. Administrators should not penalize a herd’s status for a poor sample collected by a licensed veterinarian, state, or federal official.

The Exotic Wildlife Association concludes our comments by saying that if the program standards are not significantly improved incorporating many of the suggested changes offered by the cervid industry that a meeting be held by all stakeholders involved to have candid discussions surrounding the future of the entire program. The cervid industries cannot be the sole stakeholder to bear the total burden of the existing program.

Respectfully submitted,
Exotic Wildlife Association