109 Cape Cod Drive
Cary, NC, 27511
May 12, 2014
Gordon Myers
Director
North Carolina Wildlife Resources Commission
1701 Mail Service Center
Raleigh, NC 27699-1701
Dear Gordon:
Firs, thank you for the opportunity to serve on the Cervid Disease Task Force and for this
opportunity to comment. As you may know, I have had considerable experience with the
captive cervid industry, from venison farms to hunting operations to research facilities. I
worked at the Colorado State deer facility in 1967 when Chronic Wasting Disease
(CWD) was discovered, having been transmitted from sheep with scabies held in the
same facility. Later I did my doctoral work at Penn State at their 200-animal deer
research facility. As a faculty member at Texas A&M-Kingsville, I established a captive
deer research facility, worked with the Texas venison industry and deer hunting
operations, and toured the New Zealand industry on a USDA grant. As department head
at Mississippi State, I worked with others who conducted research in their captive whitetail facility, and helped establish a fledgling venison industry there. Years ago I also
testified before the Oregon Game Commission on behalf of the venison industry. I have
known and collaborated with Texas Drs. Jim Kroll and Don Davis, strong proponents of
the captive cervid industry. Subsequently, I served as national President of The Wildlife
Society, department head at Texas A&M University, and Dean of the College of Natural
resources at NC State. I am also a Professional Member of the Boone & Crocket Club
and lifelong hunter.
Over my 43-year professional career, I have changed my views on the captive cervids.
Although I support the need for captive cervid research facilities, I oppose all other deer
farming and ranching activities. There are a myriad of reasons I have to oppose
enclosing, breeding, feeding, baiting, vaccinating, marking or otherwise handling or
hunting captive native cervids, as you have heard and read in our meetings. Here,
however, I will focus on just one – Chronic Wasting Disease.
Although the North Carolina deer farmers were promised the ability to import deer,
expand their facilities and license new farms if they followed regulations, times have
changed. The outbreak of CWD in Pennsylvania, a state with regulations similar to ours
indicated that our regulations are not strong enough. There is evidence that CWD can be
passed from one species to another (sheep to deer and why not vice versa?); that CWD
can show up in herds long after the 5-year testing period; that there is no way to insure
captive deer will not escape (fallen trees on fences, gates left open, etc.); that disease can
pass through fences that are intact (again scabies in sheep to CWD in deer); and that no
facility can truly be “certified” CWD free.
To me the bottom line is, what are the pros and cons of instituting the proposed rule
changes, or even of allowing deer farming to continue in North Carolina? I believe this
to be a cost-benefit analysis. The only advantage of changing the current rules would be
an economic one to a small group of current NC deer farmers. Of the 37 current farms,
only 13 have more than 10 animals, and only two have over 50 animals. Only 32% of the
captive animals are white-tails. This is obviously a minimal industry in North Carolina,
though it could expand. Allowing the importation of cervids and the expansion of the
industry would have no economic, sociological or ecological benefit to our native
wildlife or to our citizens.
Hunting and wildlife watching, however, are major industries in our state. If we no
longer allow the import of native or exotic cervids, and if we refuse to permit additional
deer holding facilities, we help to protect this multi-million dollar hunting and wildlife
watching industry, our $ 9.2 billion animal agriculture industry, and we help to protect
one of our major wildlife natural resources. I see no logical reason to why the citizens of
North Carolina would want to take this risk. Such a ban, however, would economically
impact those few current deer farmers who derive income from this business. I should
note that even Texas does not allow the importation of native cervids.
I therefore recommend that we:
1. Grandfather all current deer farming operations to allow them to continue to
maintain their herds and to export deer to other states.
2. That we increase the fines for importation of live cervids to $ 5,000 per animal.
3. That we cease the fawn rehabilitation program.
4. That we require extirpation of all animals in any captive herd which test positive
for CWD.
5. That we not allow the importation of any cervids from any other state.
6. That we no long issue permits for expanding current captive deer facilities or the
initiation of new facilities.
7. That we initiate a fee structure such that the costs of inspecting deer farms are
born by the deer farmers.
8. Seek means of funding a buy-out program for current deer farms and an insurance
program to compensate deer farms for deer herds that may have to be extirpated.
We may not be able to keep CWD out of North Carolina altogether, as wild deer can
cross state lines. However, the risk to allowing the captive cervid industry to continue in
this state far outweighs any benefits to our people or our wildlife.
Sincerely,
Robert D. Brown, Ph.D.