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TWRA ELK RESTORATION PROJECT

I am posting the following information because there are many people who are very confused about the TWRA elk project.

The Cervid Industry is not against the elk restoration project. We are against the unsafe and risky importation of elk that do not meet all of the rules and regulations for safe importation because it would put the state's wildlife and the farmers livestock at risk for disease.

TWRA, TWRC and TWF should be setting an example of how to follow the rules and regulations instead of ignoring the laws. These laws were put into place to ensure the safe movement of healthy animals and to reduce the risk of disease being spread all over the country. TN has many valuable resources and we need to ensure that these resources are protected.

Below you will find all of the rules and regulations that pertain to the importation of elk for the U.S. and also for TN and you will also find the reasons why the elk in question do not meet the requirements.

David L. Autry

***************************************************************************************

U.S.D.A. IMPORT PROTOCOL

File name: Canada_Cervids.doc

1. GENERAL REQUIREMENTS

1.1 No import permit is required if the cervids are offered for entry at a land border port and meet one of the following conditions: (a) were born in the U.S. or Canada and have been in no other region, or (b) were legally imported into Canada from some other region and have been unconditionally released and eligible to move freely within Canada for at least 60 days after such release. In any other case the importer must obtain an import permit from the U.S. Department of Agriculture (USDA), Animal and Plant Health Inspection Service, Veterinary Services, National Center for Import-Export, 4700 River Road, Unit 39, Riverdale, Maryland 20737-1231.

1.2 An official health certificate is required. The official health certificate must be issued by a veterinarian designated by Canadian Food Inspection Agency (CFIA), and must be endorsed by a veterinarian employed by CFIA attesting to the certifications and tests required in this protocol.

1.3 Cervids described on the health certificate are all captive farmed. Animals born in the wild are ineligible for entry under this protocol. Properly identified cervids under 6 months of age, traveling at the side of their dam, are exempted from the test requirements.

1.4 All cervids must be identified with an official unique individual eartag or tattoo, and must also have a large readable bangle eartag which allows the bangle numbers to be checked without offloading the animals. Bangle tag numbers and corresponding official tag or tattoo numbers must be recorded on the health certificate.

1.5 The health certificate must contain the certification statements as listed in the following section. The dates and results of the tuberculosis and brucellosis testing must be recorded on the health certificate.

2. CERTIFICATION STATEMENTS

2.1 Canada is free of foot-and-mouth disease, rinderpest, contagious pleuropneumonia, and surra.

2.2 Continuous records of animal identification and herds of residence of the animal being exported from the time of birth until export were verified.

2.3 Herd of origin status:

(a) Chronic wasting disease has never been diagnosed in the herd of origin.

(b) The herd of origin is a tuberculosis herd of negative status according to the provisions of the CFIA captive ungulate program, and there has been no direct no indirect contact between the herd of origin and any known tuberculosis (Mycobacterium bovis) infected source.

(c) The herd of origin is located not less than forty (40) kilometers from any known Mycobacterium bovis, Brucella abortus or chronic wasting disease infected wild population.

(d) The herd of origin does not contain animals from any herd where tuberculosis (Mycobacterium bovis), or brucellosis (Brucella abortus) has ever been diagnosed.

(e) Neither tuberculosis nor brucellosis has been diagnosed on the premises of origin during the five (5) years preceding the start of testing for export.

(f) On the premises of origin, there are no M. bovis susceptible ruminants, that have not attained the status of a herd officially recognized free of tuberculosis or a herd of negative status for tuberculosis under the Canadian Animal Health Program for Farmed Cervids.

2.4 The animal intended for export is not the direct offspring of an animal that has been diagnosed with chronic wasting disease nor has it resided at any time in a herd in which the disease has been diagnosed.

2.5 If less than one year of age, the animals intended for export were natural additions to the herd of origin.

2.6 Animals intended for export which were added to the herd of origin, except natural additions or animals from other tuberculosis herds of negative status or U.S. Accredited Free herds, have been included in a recertification test.

2.7 During the 60 days prior to export to the United States, the cervids selected for export and the herd of origin remained free from symptoms of infectious or contagious disease, and free of any known exposure to such disease.

3. TESTING REQUIREMENTS

3.1 Tuberculosis - Within 60 days prior to export, each cervid must be tested with negative results for bovine tuberculosis using the Canadian Mid-Cervical Test (MCT). Any cervid classified as a responder to the MCT is ineligible for entry. However, if the status of all responders can be established by comparative testing, or by post-mortem examination and tissue culture, negative contact animals may be considered for entry.

3.2 Brucellosis - Within 30 days prior to export, cervids must test negative to a buffered plate antigen test for Brucella abortus. Should an animal test positive, it is ineligible for entry. It must be removed from the group and test negative to a complement fixation test at a dilution of 1:5 in order for the test negative contact animals to be considered for entry.

4. PORT OF ENTRY INSPECTION

Cervids for U.S. entry must be presented to the port by appointment. The port veterinarian shall conduct a visual health examination of the cervids and verify individual identification and the correctness of the health certificate.

************************************************************************************

Re: TWRA's unsafe elk from Elk Island in Alberta Canada

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.

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

John.Clifford@aphis.usda.gov wrote:

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.

Sincerely,

John R. Clifford
Deputy Administrator
Veterinary Services

*********************************

David Autry
om> To
John.Clifford@aphis.usda.gov,
02/09/2007 06:04 ron.dehaven@aphis.usda.gov,
AM Allen.M.Knowles@aphis.usda.gov,
Andrea.M.Morgan@aphis.usda.gov,
Andrew.L.Malone@aphis.usda.gov,
Catherine.S.Fulton@aphis.usda.gov,
Jere.L.Dick@aphis.usda.gov,
Sharon.M.Coursey@aphis.usda.gov,
Beth.E.Gaston@aphis.usda.gov
cc
nick.todd@state.tn.us,
philip.gordon@state.tn.us,
Ron.Wilson@state.tn.us
Subject
TWRA's unsafe elk from Elk Island
in Alberta Canada

Dr. Clifford or anyone within the U.S.D.A.,

Has a decision been reached yet? If so, what was the decision?

David L. Autry

John.Clifford@aphis.usda.gov wrote:

David-

No decision has been made.

Sincerely,

John R. Clifford

David Autry
To
John.Clifford@aphis.usda.gov
02/03/2007 12:52 cc
PM ron.dehaven@aphis.usda.gov, Ron
Wilson ,
philip.gordon@state.tn.us, nick
todd ,
Allen.M.Knowles@aphis.usda.gov,
Jere Dick
,
Andrea.M.Morgan@aphis.usda.gov,
Sharon.M.Coursey@aphis.usda.gov,
"Ms. Catherine Fulton"

, "Mr. Andrew Malone"

Subject
Re: Fwd: elk from elk island

John,

As a taxpayer, I am disappointed that I have spent over six weeks
corresponding with you and your department about this issue and I don't
have any more answers now than I did when I started. Today I ask a simply
yes or no question and still no answer.

Dr. Luterbach, a C.F.I.A. employee, has already stated to me in one of his
phone calls over a week ago that these elk from Elk Island do not meet the
U.S.D.A. import protocol and in looking over the protocol, I can see
several areas where these elk do not qualify for importation into the
U.S.,
specifically 1.3, 2.d and 2.2.........please refer to my previous email
for
the details. Also there is the issue of no whole herd TB test.

I have been patient with your department but I now feel that I am wasting
my time as well as yours as your department has not been forthcoming with
any answers so I feel that I have exhausted all but one avenue of hope.

I feel that I have no other alternative but to seek an emergency
injunction
to prevent these elk from crossing the Canadian U.S. border because they
do
not meet the U.S.D.A. protocol and if these unsafe elk are allowed to be
imported and disease breaks out, it will be devastating to both the
wildlife and livestock in the states like WI, TN and any surrounding state
where these animals are released. As a farmer and a hunter, I can not sit
back and watch this happen.

These rules, regulations and protocols were put in place for a reason and
that was to ensure the safe movement of healthy animals to prevent the
spread of diseases and these should apply and be forced on all not just
some. Wildlife Agencies should not be allowed to import any animal that
does not meet all of the protocol.

Unless I hear from you or your department by noon Monday 2-5-07 stating
that this shipment of elk from Elk Island has been stopped and will not be
allowed to be imported into the U.S., I will assume that my concerns have
been ignored and that the U.S.D.A. is still considering these elk for
importation even though they do not meet all of the protocol and I will
then proceed accordingly.

Please do not take this as a personal attack on you as that is certainly
not my intentions. My actions will be taken as a result of your
department's inability to follow this protocol and the knowledge that your
department has ignored the many taxpayers who have contacted your
department with concerns of the possibility of these unsafe elk entering
the U.S.

Sincerely,
David L. Autry

John.Clifford@aphis.usda.gov wrote:
David,

I am not able to answer your question until we complete our discussions
here and with Canada.

Thanks,

John
--------------------------
Sent from my BlackBerry Wireless Handheld

----- Original Message -----
From: David Autry [elk4sale@yahoo.com]
Sent: 02/02/2007 12:06 PM
To: John.Clifford@aphis.usda.gov
Cc: ron.dehaven@aphis.usda.gov; Ron.Wilson@state.tn.us; Philip Gordon;
nick.todd@state.tn.us; Allen.M.Knowles@aphis.usda.gov
Subject: Re: Fwd: elk from elk island

Dr. Clifford,

Thanks for the quick reply late last night. It looks like you are working
overtime on this project.

I need a simply yes or no answer to just one question. Since I can see
from the USDA import protocol that there are four or five areas where the
Elk Island herd does not meet this protocol and since Dr. Luterbach, a
C.F.I.A. employee in Winnipeg Canada, has stated to me in his phone
conversation very recently that the Elk Island herd does not meet the
U.S.D.A. import protocol and since the U.S.D.A. is still reviewing the
records of this herd that Dr. Luterbach was asked by a U.S.D.A. official
to forward to the U.S.D.A., Is the U.S.D.A. considering the possibility of
allowing the importation of these elk from Elk Island even though they do
not and can not meet the U.S.D.A. import protocol?

I need the answer to this one question in order to know how to proceed so
if you could simply give me a yes or know answer to this question sometime
today, it would be appreciated.

Sincerely,
David L. Autry

John.Clifford@aphis.usda.gov wrote:
Mr. Autry,

Thank you for the email and we have noted your concerns. We are studying
the issue and will let you know when we have all the information and have
made a decision.

Thanks,

John Clifford.
--------------------------
Sent from my BlackBerry Wireless Handheld

----- Original Message -----
From: David Autry [elk4sale@yahoo.com]
Sent: 02/01/2007 06:08 PM
To: ron.dehaven@aphis.usda.gov; john.clifford@aphis.usda.gov
Cc: Ron.Wilson@state.tn.us; Philip Gordon; nick.todd@state.tn.us;
Allen.M.Knowles@aphis.usda.gov
Subject: Fwd: elk from elk island

Drs. Dehaven & Clifford,

It looks like the USDA is trying to qualify the elk island herd as a herd
equivalent to a herd that has had a whole herd test, probably for TB and
or Brucellosis.

Are you ignoring the other 3 or 4 areas where this herd does not meet the
USDA import protocol?

Below is the info why the Elk Island 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.

4. With a fence height of 2.2 meters and with animals coming and going
over the fence, is this truly a captive herd?

5. Animals from this herd can not meet the requirement of continuous
identification records of animals from birth to export.

Please read below!

David L. Autry

*****************************

Dr. Taniewski,

Will the information listed below stop the importation from Elk Island?

2. CERTIFICATION STATEMENTS

(d) The herd of origin does not contain animals from any herd where
tuberculosis (Mycobacterium bovis), or brucellosis (Brucella abortus) has
ever been diagnosed.

http://64.233.161.104
/search?q=cache:ybgnvsxpzdIJ:www.montana.edu/~wwwcbs/tbbib.html+elk+island+tb&hl=en&gl=us&ct=clnk&cd=1

7. Choquette, L.P.E., J.F. Gallivan, J.L. Byrne & J. Pilipavicius. 1961.
Parasites and diseases of bison in Canada I. Tuberculosis and some other
pathological conditions in bison at Wood Buffalo and Elk Island National
Parks in the fall and winter of 1959-1960. Can. Vet. J. 2: 168-174.
Tuberculosis and some other pathological conditions in bison at Wood
Buffalo and Elk Island National Parks in the fall and winter of 1959-1960
are discussed. In 1959, 1,116 animals were tested with bovine tuberculin
and 151 or 13.5% showed a positive reaction. There were 436 animals
slaughtered, and 219 or 50.2% showed tuberculous lesions, and 168 or 76.7%
of these showed evidence of infection in the lymph nodes of the head.
Metritis was noted in 9 animals, 7 of which were tested with tuberculin
and 3 tested positive. Eleven cases of orchitis were recorded in bulls.
Nine of these had been tested for brucellosis (rapid serum agglutination
technique) and 7 tested positive.

http://www.pubmedcentral.nih.gov/pagerender.fcgi?artid=1680143&pageindex...

page #120

In 1947 and later, Brucellosis was diagnosed in bison from Elk Island.

http://www.pubmedcentral.nih.gov/pagerender.fcgi?artid=1585688&pageindex=1

page #168

Elk Island is an area of about 75 square miles.

http://www.pubmedcentral.nih.gov/pagerender.fcgi?artid=1585688&pageindex...

page #171

Arthritis, actinobacillosis, coelosomian & pyemia.....Hepatic lesions at
Elk Island

http://www.pubmedcentral.nih.gov/pagerender.fcgi?artid=1585688&pageindex...

page #172

orchitis & brucella

********************************************
Dr. Taniewski,

Since Elk Island is so large, about 75 square miles, and since the animals
that are confined there are wild and free to roam over this vast area and
since the animals live off what the land provides, it is my opinion that
these animals do not meet the term captive farmed. Am I correct to assume
that? Canadian officials refer to this herd as a wild herd and rule #1.3
states that: Animals born in the wild are ineligible for entry under this
protocol.

1.3 Cervids described on the health certificate are all captive farmed.
Animals born in the wild are ineligible for entry under this protocol.
Properly identified cervids under 6 months of age, traveling at the side
of their dam, are exempted from the test requirements.

http://www.pubmedcentral.nih.gov/pagerender.fcgi?artid=1585688&pageindex=1

page #168
Elk Island is an area of about 75 square miles.

*******************************************
Dr. Taniewski,

Is the Elk Island herd truly a captive herd? Animals seem to be able to
freely come and go.

http://www.naturescapes.net/perspective/alberta.htm

The bison, elk, and moose are confined in the park by a 2.2 meter fence
encircling the entire park boundary. Bison and elk are managed by the park
staff, and numbers are occasionally sold off to control the population, as
there are no large predators, such as wolves or bears, in the park. The
moose population is controlled mainly by disease. Deer are able to leap
the fence and so can come and go.

http://www.booneandcrockettclub.com/news/trophyWatch_detail.asp?area=new...

A picture of a Moose jumping over the Elk Island fence which is only 2.2
meters high. Deer and other wildlife commonly come and go over the fence.

******************************************
Dr. Taniewski,

How can an enclosure as large as Elk Island meet the following rule?

2.2 Continuous records of animal identification and herds of residence of
the animal being exported from the time of birth until export were
verified.

http://www.pubmedcentral.nih.gov/pagerender.fcgi?artid=1585688&pageindex=1

page #168
Elk Island is an area of about 75 square miles

Note: forwarded message attached.

http://mail.yahoo.com CC: shelly@nadefa.org,
Date: Mon,
From: David
Subject: elk
To: ron.dehaven@aphis.usda.gov,

Doctors Dehaven and Clifford,

I just spoke to Dr. Luterbach with the CFIA in Winnipeg MB CA by phone and
he admitted that the elk from the Elk Island herd in Alberta CA do not
meet the USDA protocol for importation into the U.S. for several reasons
but that the CFIA had forwarded information about the herd to the USDA and
that the USDA is considering the possibility of allowing elk from this
herd to be imported into the U.S. even though they do not meet the USDA
protocol for importation.

Is this true?

Sincerely,
David L. Autry

************************************************************************************

TN IMPORT RULES AND REGULATIONS

0080-2-1-.01 DEFINITIONS.

(1) For the purpose of these rules, the following definitions shall apply unless otherwise indicated herein.

(k) Entry Permits - A verbal or written pre-movement authorization for entry of livestock into Tennessee, issued by the Tennessee State Veterinarian or his agent.

(u) Official Proof of Test - Any documentation approved by the state and federal animal health officials which bears permanent individual identification of an animal and certification by an accredited veterinarian or full-time regulatory animal health employee that the animal has been tested for a particular disease

(w) Official Test - Official tests for specifically named diseases as referred to herein shall be such tests as are recognized as official by the appropriate animal health official of the state of origin and the USDA-APHIS-VS. The date of the test shall be the date the sample is taken from the animal.

0080-2-1-.02 GENERAL REQUIREMENTS AND LIMITATIONS.

(1) All domestic animals imported into Tennessee, except poultry, or those expressly exempted herein, shall be accompanied by an official health certificate or other transportation document as recognized by the state veterinarian, which shall be in possession of the driver of the vehicle transporting such animals.

(2) Domestic animals entering the State of Tennessee without proper health certificate or otherwise entering the state in violation of these rules shall be held in quarantine at owner’s risk and expense until released or disposed of as determined by the State Veterinarian.

(3) All animals entering the State of Tennessee shall meet requirements for interstate movement as set out in Title 9, Code of Federal Regulations in addition to specific requirements set forth herein.

(4) No animal including poultry and birds of any species affected with or exposed to any infectious, contagious, or communicable disease, or that originates from a quarantined area, shall be in any manner transported or moved into Tennessee; except as allowed herein or permitted by the State Veterinarian.

Authority: T.C.A. §§4-3-203 and 44-2-102. Administrative History: Original rule certified June 4, 1974. Repeal by Public Chapter 261. New rule filed June 20, 1983; effective July 20, 1983. Amendment filed November 16, 2005; effective March 30, 2006.

0080-2-1-.03 DUTIES OF COMMON CARRIERS AND OTHER HAULERS OF DOMESTIC ANIMALS.

(1) Owners and operators of common carriers and private conveyances shall be forbidden to transport or otherwise move any domestic animal into, within, or through the State of Tennessee except in compliance with the provisions set forth in these regulations.

(2) All common carriers and private conveyances transporting domestic animals into, within, or through the State of Tennessee shall be subject to inspection and may be stopped by any agent or employee of the department or any other law enforcement officer commissioned in the State of Tennessee, to make an investigation to determine compliance with the provisions set forth in these rules.

(3) All railway cars, trucks and other conveyances used for the transportation of domestic animals and poultry shall be maintained in a sanitary condition.

(4) Owners and operators of conveyances that have been used to transport domestic animals infected with or exposed to infectious, contagious or communicable diseases shall have such conveyances thoroughly cleaned and disinfected upon order of the Tennessee State Veterinarian or his agent.

Authority: T.C.A. §§4-3-203 and 44-2-102. Administrative History: Original rule certified June 4, 1974. Repeal by Public Chapter 261. New rule filed June 20, 1983; effective July 20, 1983.

0080-2-1-.04 ENTRY PERMITS.

(1) Requests for entry permits, where required by these rules, shall be directed to the Tennessee Department of Agriculture, Division of Animal Industries, P. O. Box 40627, Nashville, Tennessee 37204, and shall set forth the species, number, age, sex, and breed of the animals; consignee, consignor, the point of origin, the point of destination, and purpose of the shipment.

(2) Such entry permits, upon issuance, shall be valid for no more than thirty (30) days and shall apply only to the shipment for which requested.

(3) The entry permit number shall be recorded on the official health certificate which accompanies the shipment.

Authority: T.C.A. §§4-3-203 and 44-2-102. Administrative History: Original rule certified June 4, 1974. Repeal by Public Chapter 261. New rule filed June 20, 1983; effective July 20, 1983.

0080-2-1-.12 BISON AND OTHER RUMINANTS.

(1) Bison and other ruminants not covered herein shall comply with the requirements for “cattle” in 0080-2-1-.05, or as directed by the state veterinarian.

(2) Additional Tuberculosis Requirements For Cervidae

(a) All cervidae shall originate in herds which have had a negative herd test for tuberculosis within twelve (12) months with a USDA approved single cervical test and individual imported animals shall be negative to the single cervical test within thirty (30) days of entry; or

(b) Animals not orientating in tested herds as described above must test negative to two (2) single cervical tests at least ninety (90) days apart, the second test conducted not more than thirty (30) days prior to entry.

(3) Other Requirements For Captive, Chronic Wasting Disease Susceptible Cervidae

(a) No cervidae shall be imported from geographic areas where Chronic Wasting Disease (CWD) has ever been diagnosed in wildlife. For purposes of this rule, “geographic area” is any location where CWD has been diagnosed and the control zone around such area as defined by the Tennessee state veterinarian at the time a permit is requested.

(b) All Chronic Wasting Disease susceptible cervidae entering Tennessee must:

1. Be a member of a herd that has participated in an approved CWD surveillance program in which no CWD has ever been diagnosed nor has the herd been identified as a trace-back or trace-forward herd. The herd must have an enrollment date in the program on or before January 1, 2000.

(c) A prior entry permit shall be obtained by the issuing veterinarian from the office of the Tennessee State Veterinarian during regular office hours.

(d) The following statement must be recorded on the Certificate of Veterinary Inspection: “To the best of my knowledge, the animals listed are in compliance with the Tennessee CWD import rules for cervidae”.

(e) The owner/agent section of the Certificate of Veterinary Inspection must be signed.

Authority: T.C.A. §§4-3-203 and 44-2-102. Administrative History: Original rule certified June 5, 1974. Amendment filed April 18, 1979; effective June 4. 1979. Repeal by Public Chapter 261. New rule filed June 20. 1983; effective July 20, 1983. Amendment filed April 30, 1993; effective July 28, 1993. Amendment filed September 14, 1999; effective January 28, 2000. Amendment filed June 28, 2002; effective October 28, 2002.

************************************************************************************

The elk from Elk Island in Alberta Canada and the elk from Land Between the Lakes in KY do not meet the TN IMPORT RULES AND REGULATIONS for importation.

These elk fail to meet the TB testing and CWD monitoring requirements. If these elk had met the state's requirements, there would have been no need for a WAIVER.

The U.S. cervid industry is not against the elk restoration project but we are against the illegal importation of unsafe and risky animals that do not meet all of the importation rules and regulations because this would put the state's wildlife and our livestock at risk for disease and we will continue to oppose the importation of any animal that does not meet all of the requirements.

David L. Autry

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