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CWD Advisory Board Letter
Baiting is a  different matter, in part because it introduces an ethical dimension.  We feel the DNR is being hypocritical here on at least three counts.  First, proposed government sharpshooters (or their private contractors) would (according to the plan) be using bait piles during winter months when deer are most readily concentrated.  This baiting will take place in and around the CWD-MZ where, if the practice does actually spread CWD, the spread of disease is most likely. The DNR argument that their sharpshooting differs from baiting because all deer that come in contact with sharpshooter's bait are killed is not the whole truth.  [Sharpshooters in the past never gunned 24/7 over the 3 month winter shooting period. In fact, they only shot over individual bait piles a few hours a night and a few days a week for a few weeks a winter.]  Second, the plan ignores the fact that deer attracted to farmers' hay bales under severe winter conditions have been shot (using the bales as bait) during the extended winter shooting season.  Third, and most hypocritical of all, the DNR allows thousands of gallons of commercial attractants derived from deer urine and secretions to be spread throughout the state at will.  These completely unregulated products represent a commercial enterprise that is a lucrative cash cow (to deer farmers, to suppliers and distributors, to hunting magazines that sell ads, to retail businesses, to sales tax coffers) and a significant part of the deer hunting economy which the DNR claims CWD policy is designed to protect.  In view of the facts that deer farms throughout the country are the source of these products, that deer farms have in the past been found to hold CWD infected animals, and that researchers think that the prions responsible for CWD are shed into the environment from sick deer, this failure to ban deer-derived attractants seems like a colossal lapse of judgment. Or is it merely a case of dollars trumping principle? Whatever the explanation, it makes the proposed statewide feeding and baiting ban a sham. It also sends confusing signals that cannot help but cause people to question the DNR's true motives.

Such bewildering policy contradictions serve to undermine the people's trust and erode support. Under the present circumstances, the issue of statewide baiting and feeding should be removed from this plan.  If the DNR insists on pursuing the matter, it should be dealt with separately where it could get the full attention and discussion it deserves.
        

[5] Why precisely a 56% herd reduction?

The SAG recommended a 5-year herd reduction plan for the CWD Management Zone (MZ) that, in the spirit of adaptive management,  the members thought was achievable.  They thought a reasonable aim would be reduce the herd 20% below 2001 DMU goals by the end of the 5 years. Considering the dismal past herd reduction history, this would be a lofty achievement. The plan provides no data or calculations, so we are not able to tell how the 56% figures was determined.  This high herd reduction figure begs for explanation.

It appears that the 10 year plan calls for a 56% herd reduction in the CWD MZ (from 200,000 to 88,000 animals) from totaled 2008 GMU estimates.  Unfortunately, the DNR has not been forthright about the huge impact (starved deer, aborted/stillborn fawns) of deep snow and ice in the exceptionally long winter of 2008 in southwestern Wisconsin, and the likelihood of similar problems this winter if the abnormally deep snow cover persists.  Because the winter aerial survey of 2008 missed the severity of winter losses, and DNR personnel apparently failed to go afield or talk to landowners about the number of carcasses found in the spring, the herd estimates used in the plan are not very accurate. They will be even worse after the winter of 2009 if likely starvation losses are again not acknowledged.  Failure to admit these winter losses will result in the DNR being blamed for them.

But, if DNR herd estimates are taken at face value, a 56% reduction would result in a herd that is less than half (44%) of what hunters experienced in the field during the 2008 seasons.  Few landowners and hunters will endorse that extreme level of herd reduction.  Furthermore, the 56% figure has no "best-science" justification.  In no place in the country has there proven to be a direct relationship between deer density and CWD infection rate. And in no place in the country has any amount of herd reduction ever reduced the prevalence of CWD significantly. It looks like the DNR is using CWD as the excuse to serve its long term goal of cutting the statewide deer herd by half.

In summary, in no place in the country (or Canada) has any CWD management intervention proven able to eradicate, contain, slow the spread, or decrease the prevalence of the disease in the wild deer herd.  Indeed, with the exception of disease surveillance and research funding, most CWD policy expenditures have borne meager fruit. This is a problem.  As a rule, democratic nations simply cannot afford to chase after every potential or perceived risk.  It usually takes a serious and imminent threat to justify costly preemptive public policy.  More important, the people usually insist that their government not embark on such a policy unless it has a reasonable chance of success.

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