Thank you, Mr. Chairman, for the opportunity to share with you the Association’s perspectives on S 1366 and the status of management of Chronic Wasting Disease (CWD) in general. I am Gary Taylor, Legislative Director of the Association, and accompanying me today is Dr. Tom Thorne, a wildlife veterinarian with the Wyoming Game and Fish Department, and Chair of the Association’s Fish and Wildlife Health subcommittee on Chronic Wasting Disease. All 50 State fish and wildlife agencies are members of the Association. The Association looks forward to continuing to work with you in particular to provide the state and federal agencies with the fiscal resources that they need to manage this disease. Further, we continue to urge that decisions with respect to management of this disease be well grounded in science. We continue to stress the need for comprehensive federal agency cooperation and coordination to effectively manage this disease. And finally, we will share with you some information regarding the progress of CWD management as outlined in the implementation strategy deriving from the national plan.
The International Association of Fish and Wildlife Agencies was founded in 1902 as a quasi-governmental organization of public agencies charged with the protection and management of North America's fish and wildlife resources. The Association's governmental members include the fish and wildlife agencies of the states, provinces, and federal governments of the U.S., Canada, and Mexico. All 50 states are members. The Association has been a key organization in promoting sound resource management and strengthening federal, state, and private cooperation in protecting and managing fish and wildlife and their habitats in the public interest.
Federal and state agencies involved in this endeavor concur that, collectively, all the authorities that are necessary to manage this disease currently exist in law. While we therefore are not convinced of the need for further authorizing legislation, the Association wishes to commend Chairman Crapo, Sen. Allard, Sen. Feingold and others in particular for their diligence in ensuring that a coordinated federal – state effort is directed at this issue. What is most needed are adequate Congressional appropriations to the federal agencies involved for both their efforts and to pass through to the state fish and wildlife agencies, state universities and state agriculture departments, to manage CWD. The Association looks forward to working with you to increase appropriations for these purposes.
Let me summarize where we are in management of this disease by reflecting on the good progress that has been made over the last almost 2 years. About 2 years ago, the US Department of Agriculture and US Department of the Interior convened a federal task force to coordinate CWD management. Under the chairmanship of Bobby Acord, Administrator, APHIS, and Steve Williams, Director, US Fish Wildlife Service, they quickly recognized the need for and utility of adding state fish and wildlife agency representatives to the Task Force. That was expeditiously done and 6 working groups each comprised of federal, state and university representatives, ultimately drafted the national plan that the Task Force released to the public (“A Plan for Assisting States, Federal Agencies, and Tribes in Managing Chronic Wasting Disease in Wildlife and Captive Cervids”) on June 26, 2002. The plan proposes goals and actions and serves as a blueprint for future activities to identify the extent of the disease and management actions needed to eliminate it or prevent its spread. Let me commend Bob Acord and Steve Williams for their patience and vigilance in overseeing it, and all participants for their dedication and diligence in completing the plan.
Subsequently, an Implementation Document for said plan was produced on October 11, 2002 by a team of 3 State fish and wildlife agency representatives, 4 USDA, and 4 USDI representatives working with input from a myriad of wildlife management and animal health professionals from across the nation. The Implementation Document steps down the goals in the national plan to action items, assigns agency responsibilities, and identifies timelines and budgets for each of 6 categories of diagnostics, disease management, communications, research, surveillance, and information dissemination. This Implementation Plan effort chaired by Bruce Morrison, NE Game and Parks Commission, represents what we believe is the best and most current thinking with respect to what is necessary to successfully manage this disease. The budget recommendations were thoughtfully constructed under the constraint of “reasonable and realistic” – they are not “pie in the sky” requests. These budget recommendations are the basis for the Association’s appropriations request that we have asked each of our State Directors to encourage their members of Congress to support.
In April 2003, APHIS made available $4 Million in FY2003 appropriated funds to the State fish and wildlife agencies for surveillance and management of CWD. Approximately $5 Million will similarly be made available from APHIS in FY2004. In designing the protocol for distribution of the funds, APHIS engaged Dr. John Fischer (Southeastern Cooperative Wildlife Disease Study), Dr. Tom Thorne (WY Game and Fish Department) and myself to design an appropriate and effective process. Collectively with APHIS we arrived at a formula that established 3 tiers of States: Tier 1 includes states with known occurrence of CWD in free ranging cervids; Tier 2 includes states adjacent to Tier 1 states or states with known CWD occurrence in farmed or captive cervids; and Tier 3 includes all other states. While one could argue the need for more money in one tier versus the other, we felt this was equitable, advanced our knowledge of presence/absence of the disease which is one of the most critical pieces of information we need, and assisted with the tremendous cost of managing the disease. The solution to getting more funds to states with CWD in free-ranging cervids, of course, is to grow the appropriated dollars, a goal to which we are all committed. Many thanks to Bob Acord and his staff at APHIS for both making these funds available and for enlisting the State fish and wildlife agencies in designing an equitable protocol that will expeditiously get money to them through a cooperative agreement.
Let me now reflect a little bit on the need for continued, comprehensive federal agency participation in a more coordinated effort to manage CWD based on sound science. Attention to all Transmissible Spongiform Encephalapothies (TSE) has increased dramatically in the last year, not just because of CWD, but most recently due to the diagnosis of Bovine Spongiform Encephalapothy (BSE) in a domestic cow in Washington, and last year in Canada. Unfortunately there is a great deal of misinformation and anxiety among the general public that ill – founded federal agency proposals may exacerbate.
The Food and Drug Administration (FDA) has promulgated regulations for the rendering industry regarding the “Use of Material from Deer and Elk in Animal Feed”. We believe these regulations unfortunately hinder animal health and wildlife management agency efforts to identify new areas where CWD occurs and simultaneously increase, rather than decrease, the likelihood of CWD positive carcasses entering the non-ruminant animal food chain.
The Association believes the regulations are an overreaction and simply cannot be supported with good science. CWD is not BSE. BSE is known to be a food-borne disease and consumption of material containing BSE – contaminated tissues is the only known natural mode of transmission of BSE. For this reason, the use of materials derived from any ruminant, including cattle, sheep, deer and elk, cannot be fed to ruminant animals according to 21CFR589.2000. By contrast, CWD is known to be transmitted laterally from affected deer and elk to susceptible deer and elk; and there is no evidence CWD is a food borne disease transmissible to non-ruminant animals.
In addition to the inaccurate message it portrays, the Association is most concerned about the provision in the FDA regulation that would trigger a recall of feed or feed ingredients containing material from a CWD positive animal. This actually hinders our ability to find new areas where CWD occurs because it promotes avoidance of CWD testing, thereby increasing the chances for CWD to go undetected and for positive animals to enter the animal feed system. Experience has demonstrated that current CWD surveillance techniques can detect the disease in a new area while at relatively low prevalence but it takes higher prevalence before discovery if detection is delayed. Early detection offers greater opportunities to eliminate the disease and early detection depends on the cooperation of hunters, meat processors, taxidermists and renderers. We are concerned that the FDA regulations would hinder this type of cooperation.
Finally, the Association continues to be concerned about some draft recommendations that the USEPA has been working on in their Region 8 Office that could likewise seriously impede our ability to detect and manage CWD in wild and captive cervids. The Region 8 proposal would require certain standards and permits for treatment of wastewater from laboratory facilities handling animals or samples from animals with CWD. Labs wishing to continue or initiate work with CWD would incur huge costs to come into compliance or would have to cease their efforts related to CWD. Should this come to fruition, the Association is concerned that the next application of these standards and permit requirements would be to meat processors, taxidermists, and rendering plants. Once again, the Association believes this proposal is not science-based and seeks to impose a standard of “no risk” as opposed to acceptable “low risk”. Action of this type would seriously affect the cooperation of hunters, meat processors, taxidermists and renderers and thereby impede our ability to detect the disease in a new area. Furthermore, these same standards do not now, nor is EPA proposing that they apply to scrapie, another TSE that has been around for centuries, and for several decades in the United States.
We are hopeful that a recent EPA Record of Decision that characterizes as pesticides under FIFRA certain chemical agents used to neutralize prions ,thus allowing the EPA to grant exemptions from permit requirements for their use, will obviate the need for further regulation. We are cautiously comfortable with this approach but will continue to encourage greater coordination by EPA with the state fish and wildlife agencies, state departments of agriculture, and state departments of environmental quality.
We are further encouraged that both FDA and EPA participated in the last state-federal CWD task force meeting.
On the issue of funding, Mr. Chairman, we all agree that more is needed, and the Association is committed to working with you and Congress to make that happen. With respect to FY2005, the Association and its member state fish and wildlife agencies are requesting $19.2 Million through appropriation to USDA-APHIS to be granted to the state fish and wildlife agencies for managing CWD in free-ranging cervids. This is approximately $10 Million more than in the President’s request of approximately $19.5 million, half of which would likely go to management of CWD in captive cervid herds. We believe the needs in free-ranging cervids compels a higher appropriated amount.
With respect to expeditiously getting money to the state fish and wildlife agencies, we will work with any federal agency, but let me suggest the utility of using an agency that has an existing mechanism for getting grant money to the State fish and wildlife agencies as the most effective mechanism. As I indicated, USDA-APHIS has executed cooperative agreements for granting CWD dollars to the State fish and wildlife agencies and we support this mechanism for funds appropriated in the Agriculture Appropriations bill. In the Department of the Interior, the USFWS has a long-standing office, machinery and process for annually granting funds from several programs to state fish and wildlife agencies. It seems to us that using these existing grant mechanisms would be the most expeditious way to deliver funds to the State fish and wildlife agencies. We are appreciative that S 1366 recognizes the utility of using the existing grant mechanism in the USFWS for this purpose for any funds appropriated in the Interior and Related Agencies Appropriations bill.
Let me now turn to the heart of this effort: its accomplishments. The most important perspective, of course, is how we are doing on the ground with respect to managing this disease. We are near completing the progress report on the first year’s effort (October 2002-September 2003) as described in the Implementation Strategy and I would like to share some information and perspectives from that with you.These 12 months have seen considerable progress in research, surveillance, management and information dissemination concerning CWD, but significant additional work needs to be accomplished.
The Implementation Strategy for the National CWD Plan identified budget needs, excluding funding for environmental compliance activities, of approximately $108 Million over a 3 year period. While a significant portion of these funds are expected to be Congressional appropriations, state and tribal agencies have considerable financial commitment in managing this disease. Despite limited funding, there has been considerable interagency collaboration and accomplishment regarding CWD surveillance, management and research.
Perhaps the quickest way to get a perspective on this is to look at some expenditures for FY2003. Details on all of these activities will be in the final progress report, expected to be in circulation shortly.
In FY2003, the USDA agencies (APHIS,ARS,CSREES) expended approximately $18.5 Million. In the same fiscal year, the USDI agencies (NPS,USGS,USFWS) expended approximately $3.3 Million.
According to a survey conducted by our Association, 44 of the 50 state fish and wildlife agencies that responded spent a total of $15.2 Million in state money and an additional $2.7 Million in Pittman-Robertson funds, for a total of approximately $18 Million in FY2003.Surveillance and management represented the largest expenditures (over 50% of the total), followed by diagnostics (approximately another 20%).
In a query of state livestock health agencies, 22 states responding indicated that their expenditures in FY2003 were approximately $2.0 Million.
Thus, as you can see, there is a considerable commitment by both state and federal agencies to manage this disease.
We also have preliminary surveillance results from 2002-2003 to share with you. Every state is engaged in sampling free-ranging cervids and other ruminants.265 out of 88,935 white-tailed deer tested positive for CWD in that sampling season. 288 out of 15,937 mule deer tested positive and 39 out of 12,843 elk tested positive. Positive tests were not manifest in the other tested species.
In conclusion, Mr. Chairman, the Association looks forward to working with you to continue to improve our capability to manage this disease. Dr. Thorne and I would be pleased to answer any questions. Thank you for the opportunity to share the Association’s perspectives with you.