NDA Submits Comments In Support of Texas Captive Herd CWD Changes

July 12, 2022 By: Torin Miller

The National Deer Association (NDA) recently submitted comments to the Texas Animal Health Commission (TAHC) in support of the TAHC’s recently proposed amendments to clarify, correct and update information regarding chronic wasting disease (CWD) management and the CWD Herd Certification Program (HCP) in Texas.

The NDA outlines deer diseases as a critical focus area and slowing the spread of CWD is of primary concern. CWD is one of the largest threats to wildlife conservation that we have encountered over the last century. As many states have learned, slowing the spread of this always-fatal disease is a daunting task and early detection and rapid response once the disease is found is critical for long-term management. Through our extensive work on this issue across North America, we know that proactive, science-based management by state wildlife and agricultural agencies is imperative to keeping prevalence rates low, deer populations healthy and hunter engagement stable.

We support the TAHC’s proposed amendments to add and/or modify definitions regarding CWD exposure status and facility inspection. Similarly, we support amendments to the state’s HCP strengthening language regarding escaped cervid reporting procedures, herd status levels, identification requirements, and inventory and subsequent inspection requirements. These amendments clarify Texas’s HCP and bring the program up to federal standards.

It’s incredibly important that state captive cervid CWD management programs, at minimum, meet federal standards. Undoubtedly, the federal HCP has its own shortcomings, and the NDA has been working with the United States Department of Agriculture and others to address needed updates. Still, we encourage states to meet, and ideally exceed, federal standards, and we encourage the TAHC to continue to take a hard-look at its own HCP on a consistent basis.

The NDA appreciates the TAHC’s proactive and aggressive approach to managing CWD, including the proposed amendments that clarify and strengthen definitions and meet federally-determined captive cervid standards. These actions should advance Texas’s effort to reduce the disease risk to the state’s wild deer. We encourage the TAHC to continue to work collaboratively and in cooperation with the Texas Parks and Wildlife Department and other state agencies, and applaud the continued inclusion of the interests and involvement of various stakeholder groups.

About Torin Miller:

Torin Miller is a licensed attorney and NDA’s Director of Policy. He works at the intersection of conservation and natural resources law, policy, advocacy and education. He has a bachelor's degree in wildlife and fisheries science from Penn State University, a J.D. from Penn State Law and is finishing a master's degree in wildlife and fisheries science at Penn State. Torin came to NDA via the National Deer Alliance, where he served as the Policy and Outreach Coordinator.

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