 |
|
ATTACHMENTS TO THE 10-YEAR PLAN LETTER [A] Why not the whole truth? Attachment A B C D E F G The authors of the plan took many liberties with democratic notions of transparency. Standard talking points, rather than full portrayal, fill the plan. In some cases key information was omitted, while in other cases the factual evidence was stretched. Half or partial truths do not make for good public policy. The following are just a few of the dozens of examples that could be cited to illustrate this practice: The plan states: "CWD is consistently lethal, ..." [Draft, Page 7, col 2, first bullet]; "Preliminary findings from research in Wyoming .... have documented lower survival rates among CWD positive animals." [Draft; page 8, col 1, last para, last sentence] Clarification: The first statement is deceptive because it suggests that CWD threatens to reduce the deer herd. In no region where CWD has been found has this been scientifically documented. Deer that progress to the chronic stage (where they look and act sick) will certainly die. But data from all states and provinces indicate that very few wild deer progress to the final disease stage. Indeed, on average, for every 100 deer that have tested positive for CWD, less than 10% are reported to appear sick. The operative point is that the vast majority of wild deer that would test positive for CWD will die from other causes (hunters, accidents, vehicle crashes, predators, starvation, other diseases). In response to a citizen's request in February 2008, the DNR provided records on only 61 deer known to have reached the chronic (sick) stage over the past 7 years of surveillance - only 61 out of a deer herd that the DNR estimates to exceed 1.5 million yearly. Many of these chronic animals were killed by DNR agents in response to calls from citizens who observed sick deer. Clarification: Although the first statement says CWD is always lethal, the second statement says survival rates among CWD positive animals are lower. How can any deer survive a disease that is said to kill all infected animals? Why the inconsistency? The plan says: "There is declining political and social support for the extent and duration of deer population reduction that likely would be needed to eliminate CWD." [Draft, page 3, col 2, last sentence] Clarification: The last part of this sentence suggests that the goal of eliminating CWD is possible but not practical. Yet, in no place in the country has any amount of herd reduction reduced the prevalence of CWD significantly. The plan alludes to a threshold herd density (derived at through speculative computer modeling) below which CWD might disappear, but evidence-based science provides us with no such threshold. In reality, any thought of eliminating CWD is still fantasy unless there are no deer in the state to be infected. Thus, planting the idea that CWD eradication is possible in the mind of the reader sets a deceptive tone. The plan says: "The goal, specific objectives, and management actions established for addressing CWD were developed based on the best scientific information currently available." [Draft, Page 5, col 2, last paragraph, first sentence]; and later it says "... studies of Wisconsin wild deer using spatial analytic tools and real-world data from Colorado and Wyoming show that without control efforts, CWD prevalence can reach high levels, and that CWD spreads geographically. Additionally, both the analytic modeling and the Colorado and Wyoming monitoring suggest CWD can reduce deer populations. Prevalence in adult male mule deer on some local winter ranges in Colorado more than doubled during a six year period (1997-2002), reaching levels of 25-40%. An ongoing study in a high prevalence population of mule deer in Colorado is reporting reduced adult survival due to CWD that is sufficient to have produced the observed population decline. Preliminary findings from research in Wyoming have estimated a prevalence of 27% among white-tailed deer ..." [ Draft, last para page 7 - first para page 8] Response: The plan's authors are using the mention of science as window dressing in an attempt to lend credibility and authority. Peer review and replication of results are the hallmarks of good science. Little CWD research has yet to stand such rigorous scrutiny over time. Furthermore, individual scientists usually disagree on what is the best science in their respective fields, especially when tackling relatively new, complex and mysterious phenomena such as CWD. The draft plan provides no citations to scientific literature, and with respect to the key issues mentioned in the second quote it refers only to unpublished spatial analytic tools (speculative computer modeling), on-going projects, and preliminary findings. It is frustrating that mule deer in open western ranges are being compared to whitetail deer in midwestern forest/farm country, and the size of "local winter ranges" is not given. More troubling still, we are not aware that any of this material has undergone peer review or replication by other scientists, yet it is being presented as foundation "best-science" justification for a decade-long plan. This makes us uncomfortable. This material has some interesting history. When it was presented to the SAG committee by one of the technical team members, several stakeholders asked to be provided with the original scientific source material, as had been done with all of the science team members. Repeated requests were ignored, so there was no way to evaluate the context and validity of the statements on normal scientific grounds. When essentially the same material later was written into the final SAG report by a paid DNR consultant, it was publically challenged by several stakeholders. But, according to the rules the DNR dictated, SAG members were prevented from altering in any way a report that was supposed to be their own. The plan says: "Increasing scientific knowledge about CWD has been a major priority of the Department since the disease was discovered in the state." [Draft, p 13, col 1, para 3, first sentence] Response: Funding allocations say otherwise. According to the Legislative Audit, of the approximately $35 million spent, only about $1.5 million (less than 5%) went to research, and nearly half of that was spent on a series of opinion surveys. Basic prion (protein) research was funded by outside sources, but the DNR spent relatively few dollars researching CWD in the wild deer herd. The DNR actually reduced funding for the most visible field project, the multi-year deer movement study. In our opinion, to say research has been a major priority is an exaggeration. |