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ATTACHMENTS TO THE 10-YEAR PLAN LETTER [D] Living with CWD possible People of Wisconsin have quickly adjusted to CWD in the deer herd, just as people have adjusted in other states. In spite of dire predictions of a collapse in hunting and the hunting economy whenever CWD is found in new areas of the country, oppressive and costly CWD policy has had a more lasting impact than CWD itself. Hunters have generally been able to move beyond scare tactics and their initial fear of the unknown and adopt a more rational view of the disease. The evidence is compelling. States such as Colorado that have dealt with CWD for decades report no decline in applications for hunting permits in known CWD zones. Where testing is voluntary or where it requires a fee, most hunters do not bother to have their carcass tested. The general conclusion is that CWD policy is a bigger threat to the deer hunting culture and economy than the disease. Complicated seasons and regulations, aging hunter demographics, deer herds devastated by unlimited killing, reduced access, and ongoing destruction of deer habitat are the biggest immediate threats to hunting. Where CWD is found, it falls far down the list. [E] CWD health risk exaggerated We now know that Wisconsin CWD policy since 2002 has been based on wildly exaggerated disease risk claims. Current evidence paints a much different picture in two regards. With respect to risk of exposure to CWD, there are no documented risks to humans, livestock or companion animals associated with handling or eating deer infected with CWD. The science team told SAG that if an unknown risk does exist, the best guess is that it is small. For those seeking to minimize the possibility of a risk yet to be determined, not eating any venison that yields a suspicious or positive reading on any available test is the most desired precaution. Yet, the WDNR still refuses to report suspicious screening test results immediately to hunters, in spite of the fact that it is routine practice in other states. The WDNR insists on getting a confirming result using a different and time-consuming test before alerting hunters that their venison tests positive for CWD. We object to this arbitrary bureaucratic delay. With respect to the impact of CWD on the deer herd, the SAG committee was told by the science team that the impact of CWD on deer numbers was likely to be slight or negligible for decades, if not centuries, to come. [In contrast, the plan exaggerates the threat, saying: "The effect of CWD on the wild deer population over the next decade may be low."] DNR-supported deer-movement research indicates that CWD is even difficult to transmit within social groups where deer spend their lives in constant social interaction. The disease certainly does not spread rapidly across the landscape like an raging wildfire (the DNR's favorite image). The bottom line is that few deer that become infected in the wild are likely to die from CWD. Some deer show resistance to infection, while others are able to live with the disease for years. In the foreseeable future, the effects of CWD in the wild do not appear to be severe enough to outstrip the host of more mundane threats to deer survival. Extreme CWD policy looks to be a far greater threat to the deer herd than the disease. [F] Was the SAG effort wasted? Stakeholders were called in to help the DNR after policy failure was widely acknowledged in the summer of 2007. The unpaid citizen volunteers from around the state spent a great deal of time, effort and money in a good faith effort to provide the DNR with their insights on how better to shape future CWD policy around the will of the people. It would be natural to wonder why some of the strongest SAG recommendations were disregarded in developing the 10 year plan. We do not pretend to know the minds of the plan authors. But we do know that halfway through the SAG process certain CWD officials, including in particular some DNR technical advisory team members, began to mock the citizen stakeholders and dismiss their contributions during SAG meetings. The stakeholders were told that the DNR, in the end, could and would do whatever it pleased in spite of the long and costly SAG process. Things eventually got so out of hand that meetings were disrupted and the SAG process was delayed, requiring more than the scheduled meetings to complete scheduled business. In order to maintain Robert's Rules of Order, SAG members eventually instructed the technical team to remain quiet unless asked a direct question. This prompted some DNR personnel to walk out of the room, not to return. Several public observers at these meetings later mentioned to SAG members how appalled they were with the unprofessional behavior of these government (state and federal) employees. That these same individuals were key players in developing this 10 year plan is evident in the misleading language used to characterize SAG input. [G] Management strategy, not contain strategy The 10 year plan exhibits a misleading strategy confusion. A little history is telling here. The McCallum/Bazzell team set out to eradicate the deer herd, a clear impossibility without declaring martial law. The Doyle/Hassett team backed off to a disease eradication goal, which had (and has) yet to be accomplished anyplace in the country and was as improbable as herd eradication. Not surprisingly, neither herd nor disease eradication was achieved. In reality, the operational strategy in both administrations ended up being nothing more than surveillance, testing, research, food pantry donations and education. The SAG committee debated the matter at length and determined that CWD control was also impossible for two reasons. First, we do not know the true distribution of CWD in the state (we currently are guessing based on inadequate sample data). And, second, containment would require building a physical barrier or creating a 100-mile-wide no-deer zone surrounding that disease distribution. Of course, neither such barrier is realistic. So SAG decided that a pragmatic disease management strategy based on surveillance, testing, research, food pantry, and education was the only viable option. For the 2008 season the Doyle/Frank team essentially adopted the SAG suggestion, but minimized the research and education components. Although the term "managing CWD" is used in the title of the 10 year plan, the authors waffle back and forth in a confusing way between contain-control-management language in the body of the plan. In the end, the plan implies (deceptively) that CWD containment and control is possible while the DNR is still trying to determine the true distribution of CWD (a moving target), and absent a physical barrier or wide dead zone. Since the true distribution of CWD will not be known for decades (if ever), and building any type of physical barrier is ridiculous, the truth of this matter should be spelled out in the text before the plan is approved. |