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Joined: 10/15/2006
Posts: 127
TWRA appeals USDA decision

To all USDA personnel involved with the Elk Island importation request from TWRA,

Thank you for denying TWRA's request for the importation of elk that clearly do not meet the USDA protocol.

The U.S. cervid industry approves of your decision and appreciates the fact that a state wildlife agency was held to the same regulations that the U.S. cervid industry has been held to.

The U.S. cervid industry is aware of TWRA's appeal of your denial on their importation request and we hope that the USDA does not waiver on your previous decision.

TWRA's appeal refers to the amount of time and money that TWRA has invested in this project in hopes that it will influence your decision but while TWRA's investment may be significant, it does not justify putting TN's livestock and wildlife at risk for disease. It would be like comparing a grain of sand to the whole state of Tennessee. TWRA's investment on these unsafe elk is insignificant when compared to the health risk of TN's livestock and wildlife by allowing animals to be imported that do not meet regulations.

TWRA's appeal tries to imply that while these elk at Elk Island do not meet the USDA protocol that this state wildlife agency, TWRA, should be given special treatment. The U.S. cervid industry would be against any special treatment for this state wildlife agency and we feel there is no reason for unfair double standards. Our position on this issue is: Either these Elk Island elk come into compliance and meet ALL of the USDA protocol or THE USDA SHOULD NOT ALLOW THESE UNSAFE ELK TO BE IMPORTED INTO THE U.S.

While the USDA only addressed two areas that the elk island herd did not meet the USDA protocol, there are actually a few other areas where the U.S. cervid industry feels this herd does not qualify for importation into the U.S.

1. This is a wild herd and wild animals are not eligible for import under
this protocol.

2. While this may be a captive herd, it is not a captive farmed herd.

3. Animals from a herd where TB or Brucellosis has EVER been diagnosed are
not eligible for import under this protocol.

Please refer to my previous emails, listed below, for the details on these three areas of disqualification!

The U.S. cervid industry supports the ideal of having one set of regulations that are for all to follow and we hope that the USDA will hold firm on your previous decision and not allow unsafe risky animals to be imported into the U.S. that do not meet ALL areas of the USDA protocol.

David L. Autry
TN Elk Breeders Association
TN Alternative Livestock Association
Representative of the U.S. Cervid Industry


Dear Mr. Autry-

This is in response to your emails. The Animal and Plant Health
Inspection Service (APHIS) has carefully evaluated Tennessee’s request
to import a herd of elk from Canada’s Elk Island. The situation was
complex and required careful scrutiny by our staff, as well as
discussions with animal health officials from the Canadian Food
Inspection Agency (CFIA).

Our regulations state that certain criteria must be met before animals
can be imported, and by mutual agreement with the CFIA, the U.S.
Department of Agriculture has requirements for the importation of
cervids from Canada. In this case, CFIA could not certify that the herd
of origin is tuberculosis negative, according to the provisions of the
CFIA captive ungulate program. In addition, the elk did not meet
requirements for continuous records of animal identification from time
of birth until export. Therefore, at this time, APHIS cannot approve
the importation of these animals.

APHIS has the responsibility to protect the health of our Nation’s
agriculture and natural resources. We appreciate your understanding as
we examined this situation.


John R. Clifford
Deputy Administrator
Veterinary Services

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