Comment on proposed CWD changes for Texas


Exotic Wildlife Association
Membership Alert


Attention All EWA Members


Your Comments Must be Submitted to the Texas Animal Health Commission by Monday, Nov. 26, 2012


RE:  Texas Animal Health Commission (TAHC) Chronic Wasting Disease rule. The below proposed rule change by TAHC was written to meet the requirements for interstate movement of susceptible species of whitetail, mule deer, Sika, Red Deer and moose as set out in the new Chronic Wasting Disease (CWD) federal rule. The comment period is open until November 26, 2012.


Below are links to the proposed rules which are now open for public comment at the email format link provided below. There is also a copy of the actual rule proposal and information explaining the rule at the links given below. It is imperative that you make every effort to post your written opinion on these proposed changes as TAHC is depending upon YOUR INPUT prior to their final adoption of these regulations. Please make your comments specific to the rule proposed. Comments may also be mailed to the Commission at the following address:


Comments Texas Animal Health Commission P.O. Box 12966 Austin, Texas 78711-2966




Go to middle of page (“Rules proposed at the September 18, 2012 Commission Meeting”). Click on “Comments” (or on links given below).  Submit your comment in the email format provided, and click on ‘send.’


Rules proposed at the September 18, 2012 Commission meeting

Chapter 40, Chronic Wasting Disease (CWD) – Proposed changes to current CWD requirements and add new ED Declaration of CWD Movement Restriction Zone section View proposal       Comment


Or you may submit comments by fax at (512) 719-0721. Comments need to be received no later than Nov. 26, 2012.


Below are EWA’s recommendations for responses which you may want to submit in your own words.


Specifically proposed:

  • The TAHC rule as proposed requires a hands-on herd inventory of breeder deer every three years. This means that anyone participating in interstate commerce would be required to have their accredited veterinarian or animal health inspector personally inspect each animal contained in their inventory every three years.
    • The Exotic Wildlife Association (EWA) recommends that you post your public comments on record as opposing this. (EWA does support annual herd inventory reconciliation.)
  • The TAHC rule as proposed would require that deer breeder permit-holders test 100 percent of all deaths for CWD of animals that are 12 months of age or older. Currently the requirement is 16 months.
    • EWA recommends that you oppose the proposed testing change of animals that are 12 months of age instead of the current 16 months of age. The death loss at 12 months will likely be higher because of natural mortality in this age group (few CWD cases have been found in this age group). Changing the age of testing will create an additional monetary hardship on breeders.
  • The TAHC rule allows wildlife agencies to transport CWD susceptible species across state lines with only approval from the state veterinarian for the state of origin and the state veterinarian of the receiving state. Disease protocol that is required of CWD susceptible cervid producers for interstate commerce does not have to be followed by the wildlife agencies.
    • EWA recommends that you oppose this section of the rule as discriminatory. All Interstate movement of CWD susceptible species should follow the same protocol.


It is important for all of our members to comment even if you are not involved or participate in intrastate commerce because this is setting the stage for the intrastate rule that will come in the next couple of months.


For additional information, contact Charly Seale at:


Thank you for your help on this most important matter.

Charly Seale

Executive Director

Exotic Wildlife Association