ACTION ALERT for American Members!

April 19, 2018

Submit Comments for Proposed CWD Program Standards to USDA APHIS by May 30!

(Comment period extended from April 30 to May 30)


Instructions to Comment:

You may submit comments at the Federal eRulemaking Portal: Go to!docketDetail;D=APHIS-2018-0011


The NAEBA Board of Directors approved the following list of concerns on April 10, 2018. The American Cervid Alliance also unanimously approved these concerns on April 17, 2018.

NOTE: It is important to remember that if people within cervid industry have different interpretations of the proposed language and possible impacts, this will surely result in different interpretations by state animal health, state wildlife and federal animal health officials. Ambiguity has been a problem for many state industries in the last several years.

Please send an email on behalf of your ranch listing your exact concern(s). Please note your location in the email. Cite exact language and page number, if possible.

NAEBA’s primary concern is there are too many sections that include language beyond the scope of USDA APHIS Federal CWD Rule (CFR 9 Parts 55 & 81).  Furthermore, the speculative language could very easily be used as tools against our industry to suggest more restrictive programs at the state level. Unfortunately, this is not hypothetical speculation but has actually already occurred in several states since 2012.  

USDA APHIS has made several positive changes in the new document. NAEBA appreciates APHIS has removed suggested language for ten-foot fences.  APHIS has removed several references relating to secondary barriers. These are both examples of suggested language that is in excess of CFR 9 Parts 55 & 81.  NAEBA also appreciates the clarifications made to avoid “spider web trace outs.” In the last five years, the cervid industry has seen several state animal health and wildlife officials implement draconian responses to CWD discovery with multiple layers of trace outs that crippled commerce in the whitetail deer industry.   The proposed Program Standards is now allowing ante-mortem testing for certain circumstances in whitetail herds. NAEBA believes this is a step in the right direction to avoid unnecessary depopulation of animals with values well beyond APHIS’ cap for indemnity funds. NAEBA appreciates all of these positive changes.  

However, the proposed changes do not go far enough to alleviate the industry’s concerns. In fact, several new features have been added that create new problems in of themselves.  There are still many sections with language that goes beyond the scope of CFR 9 Parts 55 & 81. NAEBA truly does not understand why this document continues to violate its own federal rule.

NAEBA Board of Directors unanimously agreed the following changes must be amended in the document.

Click here for the link to NAEBA's list of concerns. 


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