SCI Opposes Mo. Moratorium On Hunting Preserve Permits

Safari Club International – Washington DC Office
501 2nd Street, NE, Washington, DC 20002 • Phone 202 543 8733 • Fax 202 543 1205 •

October 31, 2012
Tom A. Draper
Deputy Director
Department of Conservation
PO Box 180
Jefferson City, MO 65102
Re: Comments on Proposed Changes to Wildlife Breeder (3 CSR 10-9.350) and Hunting Preserve (3 CSR 10-9.560) Permits
Dear Mr. Draper:
Safari Club International (Safari Club) is extremely concerned with the proposed changes to Wildlife Breeder (3 CSR 10-9.350) and Hunting Preserve (3 CSR 10-9.560) Permits (proposed rules) published in the Missouri Register on October 1, 2012. These proposed rules would suspend the approval of both Class I Wildlife breeder permits for white-tailed deer or mule deer and licensed hunting preserve permits for big game hunting preserves. These rules would end the growth of the preserve hunting system in Missouri and over time would essential end preserve hunting in Missouri as the new rule prevents current ranchers and breeders from selling their existing operations. Safari Club is extremely concerned about the reduction in hunting opportunities that would result. While we understand the great threat that chronic wasting disease (CWD) poses to deer herds, we believe that these rules are far too broad in scope given the number and location of CWD positive deer found within the state.
Safari Club International and Safari Club International Foundation

Safari Club International, a nonprofit IRC § 501(c) (4) corporation, has approximately 53,000 members worldwide. Safari Club has three chapters in Missouri and these chapters are extremely active in the conservation and management of Missouri’s wildlife resources. Additionally, Safari club has numerous members who own and manage hunting preserves in Missouri who would be negatively affected by the
proposed rule. SCI’s mission is to protect the freedom to hunt and to promote wildlife conservation worldwide.
Safari Club has actively worked with Missouri ranches and in January of this year Safari Club raised over $125,000 from hunts donated from one Missouri ranch to support conservation programs and to provide hunting opportunities to wounded warriors through Safari Club International Foundation (SCIF). Additionally, Safari Club, SCIF, and Club chapters have donated significant resources to fund research to stop the spread of CWD throughout the United States and Canada.
The Proposed Rules are Overbroad and Needlessly Burden Missouri’s Deer Industry.

SCI strongly believes that the Missouri Department of Conservation is correct in working proactively to prevent the spread of CWD. CWD can have devastating effects on a deer herds and hunting opportunities as we have seen in numerous other states. However, SCI believes that the rules proposed by the Department of Conservation go too far and unnecessarily burden Missouri deer breeders and hunting preserves who are already proactively working to prevent the spread of CWD.

In the past two years eleven white-tail deer have tested positive for CWD on private ranches in Missouri. These deer were found on two hunting ranches 3 miles apart and both were owned by the same owner. None of those eleven deer were imported to the ranches, as all the CWD positive deer were born on the ranches. Additionally, no tagged deer that originated from other deer farms or ranches has tested positive for CWD.As a very reasonable step, the Missouri Department of Conservation worked with the ranches’ owner to depopulate most of the deer on the ranches where CWD was found and test them for CWD. The Department of Conservation also decided to test the wild deer population in a 25 mile radius around both ranches. There the Department of Conservation found five confirmed cases of CWD in free-ranging deer. This practice is in line with best practices in wildlife management and is the result that would happen in most states that are affected by CWD or have CWD response plans.
Unfortunately, rather than the measured approach that other states are taking, the rules proposed by the Department of Conservation go much further and stop the issuance of any wildlife breeder or big game hunting preserve permits as a means to stop the spread of CWD. These rules are a clear overreach due to the lack of causal relationship between the hunting ranches and wild CWD. The Department of Conservation has stated the reason for the proposed rules is to minimize the risk of spreading CWD from deer breeders and hunting preserves to the wild deer population.
However, there is no proof that the CWD amongst wild deer in Macon County came from the hunting preserve operations. It is very possible that the CWD was actually transferred from wild deer to the captive population. The Department of Conservation is assuming that because the hunting preserves found CWD first that the CWD outbreak must have originated there. However, with such a small sample size, and the fact that preserves test a greater percentage of captive
deer than the Department of Conservation tests wild deer it makes perfect sense that a preserve would find CWD first. Without establishing this causal connection, the currently proposed rule clearly goes too far. Additionally, while CWD is a threat to many states across the country, SCI could find no state where the hunting preserve industry was placed under such a harsh moratorium due to CWD.
The Proposed Rules Will Devastate the Missouri Hunting Preserve Industry and Reduce Hunting Opportunities
The hunting preserve industry in Missouri is a job creator. The industry supports approximately 300 employees and has a 200 million dollar annual impact to the state. Nationwide the deer industry is estimated to have three billion dollars in yearly economic impact. These jobs and economic impact are at risk from these proposed rules. The proposed rules would prevent the issuance of any new permits for deer hunting and breeding facilities. Therefore if a family wanted to pass a ranch on to their next generation, the family members taking over a hunting ranch would have to be on the grandfathered permit or they could not legally operate the hunting ranch. Even worse, if a family wanted to sell their ranch or hunting operation due to retirement or other life change, they would be unable to, as the new buyer would be ineligible to get a new license due to these proposed rules. The deer industry in Missouri would slowly disappear as existing operations go out of business. These preserves provide wonderful hunting opportunities to numerous hunters around the country and it would be a tremendous loss to them if these operations were allowed to wither due to unnecessary regulation.
Safari Club stands willing to help prevent the spread of CWD; however we strongly urge the Department of Conservation to reevaluate this rule and consider the impact that it could have on jobs and hunting opportunities throughout the state. We believe that working with the ranching and hunting community to stop the spread of CWD through collaborative efforts is a far better strategy then regulating the community out of business. If you have any questions concerning these comments, please contact Bill McGrath, Legislative Counsel, Safari Club International, 202-543-8733,
John Whipple
Safari Club International


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