On August 25, 2008, the Michigan departments of Agriculture (MDA) and Natural Resources (DNR) issued a press release confirming the state’s first case of Chronic Wasting Disease (CWD) in a 3-year old white-tailed deer from a privately owned cervid facility (“deer farm”) in Kent County.

Initial statements published by the Michigan Department of Natural Resources about the finding of CWD in Michigan, as part of the surveillance and response plan developed in 2002, noted that:  “…all transport of live wild deer, elk and moose will be prohibited statewide, including transport for rehabilitation purposes.  Currently, there is no live animal test for CWD, and infected animals often show no signs of illness for years in spite of being infectious for other animals.  Movement for rehabilitation purposes may speed geographic spread of the disease.”

This became an interim order by the Director, issued on August 29, 2008 and prohibiting the possession and rehabilitation of wild deer and is under consideration by the Michigan Natural Resources Commission as a permanent amendment to the state’s Wildlife Conservation Orders.

While the seriousness of this disease absolutely cannot be ignored, it is the opinion of experienced wildlife rehabilitators here in Michigan, as well as our counterparts in other states, that flat-out prohibiting the rehabilitation of deer is not a realistic, long-term solution.  In the same manner that bans against the rehabilitation of raccoons keep sick raccoons in the hands of the well-meaning but uneducated public and thereby creates a greater health risk for everyone, and the part this played in the spread of raccoon rabies faster than it would have occurred naturally due to inappropriate care and release practices, fawns in particular will now remain in the hands of far too many finders who have either no knowledge of or will willfully disregard the potential damage of CWD or other serious diseases such as Epizootic Hemorrhagic Disease and the need for its proper containment.

There must also be consideration given to the resulting tragedy of habituation, which then increases the chances that those released will, through no fault of their own, grow up to become nuisances.  And it’s not just a matter of Bambi eating the azaleas, but an increase in deer-car accidents, injuries to and the deaths of clueless deer by domestic dogs, and injuries to humans by, for example, fearless adult bucks during the rut who see humans as competition instead of predator.

We feel that the most sensible solution is to institute wildlife and wildlife rehabilitation regulations similar to those now in place to control the possible introduction of raccoon rabies, and similar to the regulations in other states where the problem of CWD has existed for some time.  This means allowing those who now rehabilitate fawns to continue to do so but with the added caveat that, recognizing that there is a shortage of wildlife rehabilitators in certain areas of the state, they can only take in fawns from within a specific, designated area and must in turn release those fawns within that same designated area.  Require that all deaths be submitted for CWD testing and, if a test returns positive, implement the same procedures used to regulate privately-owned cervid facilities.

There is already an enormous outcry being heard from the hunting community on the deer-baiting ban, and though in the opinion of many ethical hunters this an extremely unsportsmanlike activity, it is, nevertheless, seen as a means of livelihood for many in the popular hunting regions of the state.  Therefore this ban alone will be difficult to properly enforce, but is in reality a regulation that requires greater focus by law enforcement since it most effectively minimizes the risk of transmitting CWD by eliminating the congregating of large numbers of deer, in stark contrast to the small numbers handled by wildlife rehabilitators in a controlled setting, but small numbers that nevertheless create a positive perception of the state’s wildlife management efforts on the part of the general public, whether they are hunters or not.

I believe it is important to keep in mind that CWD was found in a private facility.  In my mind, and in the minds of many with whom I’ve discussed this issue, it begs the question of how CWD arrived there in the first place, and demonstrates a serious need for greater oversight of those who insist on keeping wildlife in captivity as a for-profit endeavor.  Particularly those who feel the need to keep captive species whose natural history and biology put our native, wild-living and domestic species, as well as the human population, at greater risk for these types of serious health issues.

Education must be the highest priority.  Education of the hunting community through licensing requirements and hunting permit issuance; in particular for out-of-state hunters.
Along with hunter education on the seriousness of this matter, the monitoring of hunter behavior needs to be increased.  Reports of dumping carcasses en masse must be investigated and appropriate action taken to avoid the possibility of negligent environmental contamination.  Based on simple numbers, the behavior of unethical hunters poses a FAR larger risk than the efforts of wildlife rehabilitators, whose position is to work as partners with the DNR as stewards of our natural resources.

Last, I recommend that the State of Michigan actively support, however possible, the continuation of further research into the live test for CWD in elk developed by the Colorado Department of Agriculture’s Animal and Plant Inspection Service and Colorado State University Diagnostic Laboratory to extend those findings to deer and moose.