The https://www.archerytrade.org/">Archery Trade Association advised the U.S. Department of Agriculture in November that it considers chronic wasting disease a serious threat to the nation's wildlife, and believes the USDA's CWD program should adopt stronger regulations to make disease spread rare in wild herds and captive facilities.

The ATA is also involved in an ongoing review of Wisconsin's CWD management plan, which was crafted in 2010. Since then, Wisconsin has documented the nation's most widespread CWD outbreak, and has identified areas in southern counties where over 40 percent of adult white-tailed bucks carry the disease.

The ATA believes CWD poses a significant threat to white-tailed deer, the nation's No. 1 big-game animal. Therefore, the ATA sees CWD as a direct economic threat to the archery/bowhunting industry, said https://www.archerytrade.org/about/staff/dan-forster">Dan Forster, the ATA's director of government relations.

"Whitetails are the primary objective of the vast majority of our country's bowhunters," Forster said. "But CWD's potential to harm elk, moose and all deer species could devastate these herds and significantly hurt our industry. That's why the ATA is committed to staying abreast of governmental policies and standards designed to protect the herd's health. We want to do everything possible to prevent CWD's spread."

Forster filed the ATA's concerns Nov. 15 in a formal response to the USDA's Animal and Plant Health Inspection Service during APHIS's review of standards for the nation's CWD program. The federal guidelines were adopted in 2014, and include a "herd certification program" that guides states on regulating captive elk and deer (cervids) herds. The program outlines minimum record-keeping standards for identifying, tracing, testing and monitoring captive wildlife to certify privately owned herds pose a low risk of carrying or spreading CWD.

Forster said state agencies should have more options and methods to better manage the disease in their state's cervid industry. These actions and alternatives should meet the USDA's requirements, but also let states go beyond those minimums. For instance, the ATA thinks state and federal agencies should conduct more comprehensive testing for CWD, and report/share information more systematically to better trace individual animals to pinpoint disease sources.

"One major shortcoming of the testing protocols remains the lack of testing in hunt/shooter facilities and slaughter animals," Forster told APHIS. "A validated live animal test for every (herd certification program) animal leaving a facility, or a mandatory postmortem test of all animals ever residing in an HCP program should be required. Additionally, all animals entering such a facility should be permanently identified/marked in the event an animal is involved in an epidemiological investigation."

The ATA also thinks states should be able to require secondary barriers around captive facilities to prevent escapes and nose-to-nose contact between animals inside and outside the facility. "A secondary barrier would help protect the private herd from possible infection by wild deer carrying CWD, and vice versa," Forster said. "If you have a disease-free captive herd in an area where CWD is present in the wild, double-fencing would provide additional protection for your investment."

Forster said that although science's understanding of CWD has increased the past 15 years, many aspects of the always-fatal disease remain unknown. Therefore, the nation still must do everything possible to eliminate the disease where possible, and at least slow it elsewhere.

"Eradication in captive cervids is more likely attainable with an effective disease-control and prevention program in place," Forster informed APHIS.

He also said the nation's battle with CWD would be easier if scientists develop a reliable live-animal test. "They've made some significant progress the past couple of years in live-testing for CWD, but its reliability is still not sufficient enough to use live-tests for transportation certification," Forster said. "The current live-tests still give too many false-negatives, meaning the tests don't always detect CWD in sick animals."

- Patrick Durkin, ATA