ACA Council Explores Possible Legal Options Regarding CWD Standards

August 13, 2013

From the American Cervid Alliance

No Date Scheduled for Public Comment; Industry Leader asks USDA for Extended Comment Period

Tuesday, August 6, 2013, the American Cervid Alliance convened to learn possible legal options in the event the standards document is still unacceptable after the public comment period.  The meeting’s agenda was the result of a motion made during the July 23rd council meeting by Kim Kafka of the North American Elk Breeders Association.  The Kafka motion asked that the ACA explore various legal options that may exist in this specific scenario.  Travis Lowe, who moderated the call in the absence of Eric Mohlman, said he would have a report by the next meeting. 

Travis Lowe asked a group of lawyers in Kansas that specialize in federal issues to investigate the possible legal options. Three attorneys from the firm attended the conference call and explained the possible scenarios. Council members were able to ask specific questions. 

There has been no date set for the onset of the 30 day public comment period.  Members of the Standards Working Group had believed the comment period would start in July.  As part of the routine process, the document will be subject to a public comment period that usually lasts for thirty days. After the thirty days the USDA can consider the comments and make any adjustments. The final document will then be sent for publication. 

Charly Seale, Executive Director of the Exotic Wildlife Association, sent an email asking USDA’s Dr John Clifford to extend the impending public comment period to ninety days. Seale said he believes the industry needs adequate time to digest the document and make appropriate comments.

The ACA will announce any new updates regarding the public comment process. 




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