CHRONIC WASTING DISEASE

MANAGEMENT PLAN FOR FREE

RANGING WILDLIFE IN

MONTANA

*;.**

AUGUST, 2005

) 'Wildlife <& <ParK$

Wildlife Division, Helena, MT 59620

TABLE OF CONTENTS

Table of Contents i

List of Tables iii

List of Figures iii

Glossary iv

Introduction 1

Background.

Chapter 1

1.1
1.2
1.3
1.4

1.5
1.6
1.7
1.8
1.9

Chapter 2:

2.1:

2.2:

2.3:
2.4:

Chapter 3:

3.1:

3.2:

Purpose of and Need for Action

Proposed action

Location

Need for the Action

Objectives of the Action

1.4.1 Objective^

1.4.2. Objective #2

1.4.3. Objective#3

1.4.4. Objective #4

Decisions to be Made

History of the Planning and Scoping Process

Relationship to Other Plans and Goals

Permits, Licenses, or other Authorizations Required.
Issues

1.9.1

1.9.2

Alternatives

Introduction

Description of the Alternatives

1

7

7

7

.7

2.2. 1 : Alternative I - No Action

2.2.2: Alternative II - Enhanced Surveillance. . .

2.2.3 : Alternative III - Enhanced Prevention. . . .

2.2.4: Alternative IV - Control at 1%

2.2.5: Alternative V - Control at 0%

2.2.6: Alternative VI - Aggressive Elimination.

Process Used to Develop the Alternatives

Summary Comparison of the Activities of Each

Alternative, Predicted Achievement of Objectives, and
Predicted Environmental Effects on Issue Resources

Affected Environment

Introduction

Description of Relevant Affected Resources

3.2.1: Montana' s Native Deer and Elk Populations. .

9

10

10

10

13

15

15

15

15

16

18

20

22

24

26

27

34
34
34
34

3.3
Chapter 4

4.1
4.2
4.3
4.4

4.5:

3.2.2: Wildlife Management Tools 39

3.2.3: Wildlife and Montana's Economy 40

3.2.4: Human Health 41

3.2.5: Alternative Livestock 42

3.2.6: Disposal/Environmental Contamination 44

Other Regulatory Agencies 50

Environmental Consequences 54

Introduction 54

Cumulative Impacts 54

Irreversible and Irretrievable Commitments 55

Environmental Consequences of CWD on 55

Identified Issues

4.4. 1 : Effect on Montana's Wild Deer and Elk 55

4.4.2: Effect on Wildlife Management Tools 57

4.4.3: Effect on Montana' s Economy 58

4.4.4: Effect on the Alternative Livestock Industry. .60

4.4.5: Effect on Human Health 62

4.4.6: Effect on Environmental Contamination and.. 62
Carcass Disposal
Predicted Environmental Impacts of Alternative II 63

4.5.1
4.5.2
4.5.3

Biological Environment 64

Physical Environment 64

Socioeconomic Environment 65

4.6: Predicted Environmental Impacts of Alternative III 65

4.6. 1 : Biological Environment 65

4.6.2: Physical Environment 66

4.6.3 : Socioeconomic Environment 67

4.7: Predicted Environmental Impacts of Alternative IV. ... 67

4.7. 1 : Biological Environment 68

4.7.2: Physical Environment 69

4.7.3 : Socioeconomic Environment 69

4.8: Predicted Environmental Impacts of Alternative V 70

4.8. 1 : Biological Impacts 70

4.8.2: Physical Impacts 71

4.8.3 : Socioeconomic Impacts 71

4.9: Predicted Environmental Impacts of Alternative VI. ... 72

4.9. 1 : Biological Impacts 72

4.9.2: Physical Impacts 72

4.9.3 : Socioeconomic Impacts 73

Chapter 5: List of Individuals Associated with the Project 74

Chapter 6: List of Persons and Agencies Consulted 75

Bibliography 76

Appendix 1 : "Public Information Plan - Chronic Wasting 79

Disease in Montana"

Appendix 2: "Mule Deer Population Ecology and Chronic 87

Wasting Disease Study"

LIST OF TABLES

Table 1. 2.4.1. Summary Comparison of the Activities of Each

Alternative 28

Table 2. 2.4.2 Summary Comparison of the Achievement of

Project Objectives 30

Table 3. 2.4.3 Summary Comparison of Predicted Environmental

Effects 31

Table 4. CWD Survey Result Totals for Montana from 1 998

through 2004 39

LIST OF FIGURES

Figure 1 . Distribution of CWD in both captive and
wild deer and elk populations as of 2004.
(from CWD Alliance webpage, CWD-info.org) 4

Figure 2. 2004 Montana Mule Deer Distribution and

Population Estimate 34

Figure 3 . 2004 Montana White-tailed Deer Distribution

and Population Estimate 35

Figure 4. 2004 Montana Elk Distribution and Population

Estimate 37

Figure 5. Model of Deer Herds with Chronic Wasting

Disease (an average of 250 simulations) 56

in

GLOSSARY

Biopsy: Removal of tissue from a living body for microscopic examination to establish
diagnosis.

Cervid: Members of the cervidae family, which include deer, elk, moose, and caribou.

Ecological niche: The area within a particular habitat occupied by an animal in which it
interacts with other different species of animals and plants.

Emigration: To leave one area to settle elsewhere.

Endemic area: A geographical area where a disease has been present in the population for
a period of time or has become established.

Epizootic: A term used to describe a disease that attacks a large number of animals
simultaneously.

High-risk area: A geographical area identified as having a higher probability of finding
CWD within its boundaries.

Incubation period: The period of time between becoming infected with a disease causing
organism or a prion and actually showing outward signs of the disease.

Immigration: To enter and settle in a new region.

Infective dose: The amount of infectious material required to establish an infection or
disease in a susceptible animal.

Morbidity: An unhealthy condition indicating that a disease is ongoing in an animal.

Mortality: The frequency of number of deaths in proportion to a population.

Offal: Waste parts of a butchered animal.

Pathogen: An agent that causes a disease (bacterium, virus, prion, etc.)

Pathogenesis: The development of a diseased or morbid condition. Generally refers to the
mechanism by which a pathogen is able to affect the cells, organs, and organ systems of an
animal eventually causing disease.

Prevalence: The percentage of animals affected in a given population.

IV

Spongiform lesions: Microscopic "holes" appearing in the brain tissue that are
characteristic of transmissible spongiform encephalopathies.

Telemetry: The science and technology of automatic data measurement and transmission
by radio from remote sources to a receiving station for analysis. Used in wildlife biology to
locate and track animals that have been fitted with a device that sends out a radio signal.

Ungulate: Hoofed animals such as horses, cattle, swine, deer, and sheep.

Zoonotic: A term used to describe a disease that can be transmitted from animals to man.

CHRONIC WASTING DISEASE MANAGEMENT PLAN
DRAFT ENVIRONMENTAL ASSESSMENT

INTRODUCTION

This environmental assessment (EA) evaluates potential effects on the human environment
from actions proposed by the Montana Department of Fish, Wildlife & Parks intended to
prevent and/or control Chronic Wasting Disease (CWD) in Montana's free-ranging deer
and elk populations. Any actions taken, or any actions not taken per the "no action
alternative," have the potential to affect wildlife populations as well as the economic,
agricultural, environmental and social issues directly tied to those wildlife populations.
This document represents a coordinated effort using the "best science" currently available
to state and federal agencies and their scientific staffs in the development of a CWD
management plan for the state of Montana. Although we can benefit from the experience
gained in other states where actions have been taken to manage ongoing CWD problems,
conclusions regarding the success of those actions are premature at this time. Almost all
scientists and wildlife managers in states faced with ongoing CWD problems have agreed,
however, that action must be taken to prevent and/or control CWD. To be passive in the
fight against this disease can only result in decreased wildlife populations and decreased
opportunities for the enjoyment of this valuable resource in the state of Montana.

BACKGROUND

Disease has been defined as a "deviation from the normal" for a functioning organism or
their systems. Bacteria, viruses, rickettsia, parasites, and fungi, generally referred to as
"pathogens", have historically caused transmissible diseases. A new concept in
transmissible disease has emerged in the last 20 years proposing that a set of diseases called
transmissible spongiform encephalopathies (TSE's) are not caused by "historical"
pathogens, but by a protein referred to as a "prion." A prion lacks the genetic information
(DNA or RNA) that all of the previously mentioned pathogens rely on for their infective
nature. Although the "prion theory" has not enjoyed full acceptance in the scientific
community, prions have been implicated in a number of diseases in a wide variety of
mammalian species. These diseases include Kuru and Creutzfeldt-Jakob Disease (CJD) in
humans, scrapie in sheep, bovine spongiform encephalopathy (BSE or mad cow disease) in
cattle, transmissible mink encephalopathy in mink, feline spongiform encephalopathy in
cats, and CWD in deer and elk. There is no cure for any of the TSE's - all of these diseases
cause the eventual death of the affected animal.

CWD was first identified as a fatal condition of unknown cause in captive deer at a
Colorado wildlife research facility in the late 1960's. In 1978, that condition was linked to
abnormalities found in the brains of the infected deer. Those abnormalities had a
remarkable resemblance to what was observed in the brains of sheep infected with scrapie,
a TSE disease that has afflicted sheep for centuries. This finding led scientists to conclude
that the disease affecting the captive deer was a TSE. Field observations, proven later by
experimental studies, indicate that CWD is transmissible from animal to animal, although

the exact method or natural route(s) of transmission remains unclear. Most researchers
believe that transmission occurs when a susceptible animal is directly exposed to the urine,
feces, or saliva of an infected animal. Transmission of CWD has also been shown to occur
through exposure of non-infected animals either to pastures contaminated as long as two
years earlier by infected animals or by exposure to decomposed carcasses of animals that
have died of CWD. The role played by environmental contamination in the natural
transmission of CWD is presently being evaluated. What is known is that the prion protein
is very difficult to destroy and that normal inactivating agents such as alcohol, UV light,
heat, and oxidizing agents normally effective in destroying bacteria, virus, etc. are much
less effective in destroying the prions. Because of this, prions may remain in the
environment for much longer than the classical pathogens.

CWD was first recognized as a disease in a free ranging elk in Colorado in 1981 and in
Wyoming in 1985. By 1990, CWD had been found in free ranging mule and white-tailed
deer in both states. Although the disease seemed to remain relatively localized for two to
three decades within northeastern Colorado and southeastern Wyoming, appearance of
CWD in captive game farm elk in Saskatchewan in 1996 preceded findings in game farms
in South Dakota, Colorado, Oklahoma, Montana, Nebraska, Kansas, Wisconsin,
Minnesota, New York, and in the province of Alberta. The movement of captive deer and
elk by the game farm industry has been implicated in the spread of CWD to both captive
cervids and free ranging cervids in other states. Increased surveillance efforts for CWD by
many states may also have added to the known geographical distribution of CWD in the
United States outside the original endemic area. In addition to Colorado and Wyoming,
CWD has now been detected in free ranging deer or elk populations in Nebraska, South
Dakota, Wisconsin, Illinois, Utah, New Mexico, New York, and in the province of
Saskatchewan.

The minimum incubation period prior to the observation of clinical signs in animals
experimentally infected with CWD is 15 months; incubation periods are variable and may
exceed 25 months in deer and 34 months in elk (Williams et al. 2002a). The time course
to observation of clinical signs, however, appears to be inversely related to the infective
dose, so experimental data probably underestimates the incubation periods seen in natural
infections (Williams et al. 2002b). Clinical signs in infected animals include weight loss,
increased drinking, increased salivation and drooling, lowered head, drooping ears, and
behavioral changes. Because these clinical signs mimic those seen in animals affected by
other diseases, the only way to accurately diagnose CWD in deer and elk is by direct
examination of either a section of the brain (obex) or of specific lymph nodes (lymph nodes
of choice for diagnosis are retropharyngeal lymph nodes) from the affected animal.
Previously, positive CWD diagnosis was accomplished by either microscopic examination
of the collected tissues for evidence of characteristic "spongiform lesions" or by a
technique employing specialized staining of the tissues called immunohistochemistry
(IHC). Recent advances in diagnostic techniques, including development of an enzyme-
linked immunosorbent assay (ELISA) for diagnosis of CWD, have decreased both the cost
of performing the test and the time required to provide results. These advances in testing
methodology and efficiency have come at a time when more states across the U.S have

either experienced CWD in their wildlife populations or have become concerned about it's
possible presence resulting in dramatically expanded surveillance programs for CWD.

There is a good deal of work going on in the United States and around the world focused
on the development of a diagnostic test for CWD and other TSE's. The goal of that work is
to develop a diagnostic test that can be performed on a sample that can be collected from a
live animal. Recently, a Canadian company announced progress in the development of a
test that detects a specific protein in the blood of mammals that may indicate, among other
things, infection with a TSE.

CWD remained limited in distribution to Colorado and Wyoming for 20-30 years.
Although it was a new disease and of interest to researchers, effects on the deer and elk
populations were thought to be minimal and there was little concern regarding public health
or environmental issues. Experience with another TSE in the United Kingdom, however,
brought international attention to the prion diseases when BSE (mad cow disease) was
associated with a condition in humans called variant Creutzfeldt-Jakob disease (vCJD).
Although sporadic CJD has occurred in the human population at a rate of approximately 1
per one million people for at least the last century, vCJD was suddenly implicated as a
disease that was transmitted to humans from BSE infected cattle. Whereas sporadic CJD
did not seem to be transmissible person-to-person and generally affected individuals 50
years or older, vCJD affected a younger population, seemed to be transmitted through
eating contaminated meat from BSE affected cattle, and caused some distinguishing
diagnostic characteristics in its victims allowing differentiation from sporadic CJD. As of
December 1, 2003, a total of 153 cases of vCJD had been reported in the world: 143 from
the United Kingdom, six from France, and one each from Canada, Ireland, Italy, and the
United States (note: the Canadian, Irish, and U.S. cases were reported in persons who
resided in the United Kingdom during a key exposure period of the U.K. population to the
BSE agent) (Center for Disease Control, 2004). Concern over direct transmission of TSE
diseases from other animal species to humans suddenly became a public issue. Public
concern over the potential connection between mad cow disease and vCJD surfaced just as
the distribution of CWD in deer and elk was increasing in the United States.

To date, there have been no cases of human prion disease that have been associated with
CWD. Because of differing experiences seen with two more common animal TSEs, BSE
and scrapie, there is a lingering uncertainty about assessing any potential risk that CWD
may pose to humans (Williams et al. 2002a). Scrapie, a TSE disease-affecting sheep, has
been found in sheep populations in many countries for at least 200 years. Although there is
a long history of human exposure to the scrapie infective agent (prion) through handling
sheep and consuming sheep tissues, including brain, there is no evidence that this exposure
presents a risk to human health. In contrast, BSE, as discussed, has been implicated in the
deaths of 153 humans due to vCJD. In the absence of complete information on risk, and in
light of similarities between animal and human TSEs, public health officials and wildlife
management professionals recommend that hunters, meat processors and taxidermists
handling deer and elk carcasses from areas where CWD has been diagnosed should take
measures to avoid exposure to the CWD agent and to other known zoonotic pathogens.
Boning game meat is recommended as an effective way to reduce the potential for

exposure. It is also recommended that hunters not consume the brain, spinal cord, eyes,
spleen, tonsils, or lymph nodes from harvested deer and elk, particularly those harvested
from areas where CWD has been identified in the free ranging populations. These
precautionary measures should serve as a "firewall" to further reduce any human risk from
CWD.

Map Last Updated "-■
6r"1f"MG5 J

CWD Infected VWId
Cervid Populations

States When* CWD
Hat Been Found in
Captive Cervid
Populations

(#) Indicates total
number of captive
herds infected. Many
have been eliminated.

Figure 1. Distribution of CWD in both captive and wild deer and elk
populations as of 2004. (from CWD Alliance webpage, CWD-info.org)

The discovery of CWD in both the captive industry (game farms) and in free ranging
populations has caused concern for those participating in or regulating the captive deer and
elk industry and for those state agencies involved with managing free ranging deer and elk
populations. Attempts to minimize the distribution of the disease or to eliminate the
disease have been initiated by both state and federal agencies. Formal discussions relative
to a State/Federal program for this disease did not develop until the United States Animal
Health Association (US AHA) passed resolutions in 1998 and 1999 endorsing a national
program as the disease began to spread through the alternative livestock industry. As CWD
was diagnosed in more and more captive elk herds (currently 39 herds in the U.S. and 43
herds in Canada have been diagnosed with CWD), the North American Elk Breeders
Association also endorsed a cooperative state and federal program and proposed a program
outline. USDA/APHIS/Veterinary Services convened a national working group for CWD
in June of 2000. This national working group developed a draft national CWD program for
captive elk, which was adopted and funded in fiscal year 2003. This program was

restricted to captive elk, offered surveillance support and provided guidance to all
participating states for eradication and control of CWD. USD A/ APHIS has now proposed
the "Chronic Wasting Disease Herd Certification Program and Interstate Movement of
Captive Deer and Elk" to eliminate CWD from captive deer and elk in the United States
(USD A/APHIS, 2003). That plan is expected to go into place in late 2005.

In June of 2002, a task force of Federal agencies and state wildlife management agencies
completed the "Plan for Assisting States, Federal Agencies, and Tribes in Managing
Chronic Wasting Disease in Wild and Captive Cervids" (USDA/APHIS, 2002). An
implementation plan, in place in 2003, provided almost $21.5 million in federal funding for
control and eradication of CWD in wild cervids. Total state expenditures in 2003 were
estimated at $15.2 million with an additional $2.7 million of Federal Aid and Wildlife
Restoration Act funding allocated at the discretion of the states. The six elements of the
implementation plan include surveillance, disease management, scientific/technical
information, communication, diagnostics, and research.

Finally, in April of 2004, wildlife and natural resource managers from 24 states developed
the "Multi-State Guidelines for Chronic Wasting Disease Management in Free-Ranging
White-tailed Deer, Mule Deer, and Elk." The suggested multi-state guidelines include
recommendations for addressing disease prevention, disease and population management,
captive deer and elk management, carcass disposal, monitoring and adaptive management,
environmental decontamination, and population restoration in plans developed by
individual states. Many of those program elements are presented and discussed in the
alternatives evaluated in this EA.

State action plans initiated by wildlife management agencies have been developed to
address potential effects of CWD on wildlife populations. CWD is unlike other diseases
that wildlife agencies have dealt with and there is limited history concerning the effects of
CWD on wildlife populations. Scientists have therefore had to rely on computerized
models to evaluate potential effects. Computerized models require the input of a number of
disease parameters, some of which are still unresolved for various aspects of CWD. Early
models have forecast declines in a cervid population once the prevalence of CWD in a
given population exceeds 5% (Miller et al. 2000). Those models go on to predict that a
given deer population of 1000 animals would experience a 10% reduction in 30 years, a
50% reduction in 50 years, and either a complete eradication of the deer herd or a 90%
reduction in 100 years due to CWD. Those predictions have been based on a frequency
dependent model where the number of contacts that an individual deer has with an infected
deer is constant and is not affected by changes in the density of the deer population. Other
models are based on a density-dependent parameter, where the number of contacts would
decrease as the density of the population decreased due to disease or other mortality
factors. The density dependent models may indicate that a reduced population density
could eventually be obtained that would be insufficient to sustain continued transmission of
the disease resulting in the disease eventually "dying out." Unknowns in the density
dependent model include the role environmental contamination may play in the natural
transmission of CWD and the effect that movement or migration of infected animals from
an infected herd to adjacent uninfected herds may have on the model outcome.

In response to the threat of CWD, and in many cases with the aid of the above-mentioned
programs and models, various state wildlife and conservation agencies have developed
plans for the prevention, control, or eradication of CWD within their borders. Options for
the management of CWD are limited. No vaccine is available to prevent infection in
susceptible animals and there are no known treatments for infected animals. The long
incubation period, possible environmental contamination with a persistent pathogen, and an
incomplete understanding of the routes of transmission limit options for control of CWD
(Miller et al. 2000). Prevention of CWD in new areas and/or elimination of new "hot
spots" of CWD infections have generally been the focus of action plans from states that
have not found CWD within their borders. If hot spots can be identified through
surveillance programs and population densities manipulated to reduce the geographic
movement of infected animals and the resulting environmental contamination in a timely
manner, wildlife managers believe that there is a chance to control the spread of CWD or to
potentially eliminate CWD. Once CWD has become established, however, eliminating the
disease completely may prove to be difficult or impossible. Attempts to reduce the
prevalence of CWD in affected areas or to completely eradicate the disease are being
pursued in Colorado and Wisconsin, respectively. Those attempts may provide insight into
control and management of CWD in wildlife populations in future years.

Chapter 1: Purpose of and Need for Action

1.1 Proposed Action

The Montana Department of Fish, Wildlife & Parks (FWP) proposes to authorize
actions intended to prevent the introduction of Chronic Wasting Disease (CWD) into
Montana, to prevent the spread of CWD if it is identified in Montana, and to "reduce"
the prevalence of CWD in specific locations if and when it is found. The proposed
actions relating to the prevention of CWD into Montana could be implemented as early
as the summer or fall of 2005 and would continue indefinitely depending on the status
of CWD in Montana and any advances concerning the pathogenesis, transmission and
potential treatment of CWD. Actions related to the control and/or management of
CWD would be initiated following the diagnosis of CWD in a free ranging Montana
deer or elk. The program would be adaptive in that changes to the program could be
instituted as levels of success acheived both in Montana's CWD management program
and with programs ongoing in other states are evaluated and more effective approaches
to CWD prevention, reduction, or elimination are identified.

1.2 Location

Diagnosis of CWD in a deer or elk harvested from a known location will result in
focused efforts taken in and around that location. Actions may also be taken on a
statewide level to prevent the introduction of CWD or the geographic spread of CWD
into new areas.

1.3 Need for the Action

FWP has been entrusted by the citizens of Montana with the preservation and
management of our wildlife resources. Included in this mandate is the identification
evaluation, and management of wildlife diseases and the effects that they have on the
health of those populations and consequently on the economy of Montana.

CWD has been recognized in free ranging deer or elk populations in the United States
since 1981. Since that initial discovery, additional diagnoses have been made in either
captive populations of deer and elk (9 states and 2 provinces) or in free ranging
populations (9 states and 1 province). These additional discoveries have been the
result of increased surveillance but also reflect an increased distribution of the disease
to new areas through either natural movements and migrations of wild populations or
through human influenced movement of captive reared and privately owned deer and
elk.

CWD is a fatal disease in deer and elk caused by a protein referred to as a prion. The
disease is transmitted from animal to animal and may also be spread by exposure of
deer and elk to environments that have been contaminated by CWD infected deer and
elk. The concept of an infectious disease that is caused by a protein is a new concept
in the field of disease. Only recently have information and new techniques concerning
prion related diseases been available to aid in the study of these diseases. The effects
of CWD on an overall deer or elk population over a given time are unknown.
Computer generated models have predicted, however, that left unchecked CWD may

reduce a deer population by 10% in 30 years, by 50% in 50 years, and by 90% in 100
years (Madson, Chris 2003).

As of August 2005, CWD has not been detected in free ranging deer or elk populations
in Montana after testing more than 7000 samples from individual animals. CWD has
been detected, however, in free ranging wildlife populations in Wyoming, South
Dakota, and Saskatchewan in close proximity to Montana's borders. Scientists and
Wildlife Managers in Montana are concerned that CWD will eventually be found in
Montana. This action plan is a proactive attempt to first prevent or slow the initial
introduction of CWD into Montana and second, to be prepared to manage CWD
effectively if it is found in Montana's wildlife populations.

1.4 Objectives of the Action

In order to meet the goals of its statutorily mandated responsibilities, the Department
has set the following specific project objectives:

1.4.1 Objective #1: Prevent the introduction of CWD into Montana's free
ranging deer and elk populations.

1.4.2 Objective #2: Minimize the spread of CWD beyond affected areas and
reduce the incidence of the disease within affected populations if it is
detected in Montana.

1.4.3 Objective #3: Provide timely, complete and accurate information about all
aspects of CWD to personnel of participating agencies and to the public in
Montana and throughout the United States.

1.4.4 Objective #4: Maintain an adaptive CWD surveillance program in
Montana to allow for the early detection of CWD and to allow for
evaluation of population involvement and management action success as the
plan itself develops in response to CWD.

This environmental analysis evaluates the ability of six separate alternatives
(Chapter 2) to fulfill the above objectives and discusses the potential environmental
impacts that may be associated with each of the alternatives.

1.5 Decisions to be Made

• Determine if the alternatives discussed in this document meet the objectives.

• Determine the appropriate alternative most likely to achieve the stated
objectives

• Determine whether the effects of each of the alternatives are significant on the
human environment and, if so, what measures may be taken to mitigate those
effects.

1.6 History of the Planning and Scoping Process

Public "scoping" meetings were initiated in March of 2004 and conducted in all
seven administrative regions of MFWP. Approximately 30 people in total attended
the various scoping meetings. Questionnaires concerning potential issues
associated with CWD in Montana were distributed to all attendees and were
returned by 20 individuals.

Presentations concerning transmissible spongiform encephalopathies in general and
CWD in particular were given to numerous groups including the Prickly Pear
Sportsman's Association, the American Association for Clinical Laboratory
Science, the Great Falls Conservation Council (BLM, MWF, Audubon, etc.),
Montana Meat Packers Convention, FWP Enforcement Division, the FWP Wildlife
Division, to the general public at a CWD Symposium held at Rocky Mountain
Laboratories in Hamilton, Montana, and to the Boy's State delegates at the 2005
Boy's State convention.

A CWD Action Plan Oversight Committee was appointed and met on multiple
occasions during preparation of the CWD Action Plan. The oversight committee
had representatives from the Montana Department of Public Health and Human
Services, the Montana Department of Livestock, and the Montana Department of
Fish, Wildlife & Parks.

Meetings were held or input obtained during the preparation of this document with
representatives of the U.S. Fish and Wildlife Service, the National Parks Service,
the U.S. Geological Survey Biological Resource Division, the Native American
Indian Tribes with land ownership within Montana's borders, the Montana Wildlife
Federation, Montana Alternative Livestock Producers, Montana Board of Outfitters,
and with private landowners.

1.7 Relationship to Other Plans and Goals

Issues regarding the management of Montana's wildlife overlap with a number of
state and federally produced management plans and directives. In 1998, the FWP
Wildlife Division completed a programmatic environmental impact statement
intended to provide a management philosophy and specific guidance as to how
FWP should approach wildlife management. Additional management plans
adopted by FWP for big game species include the 1998 Deer Management Policy, a
2001 Adaptive Harvest Management Plan for mule deer, and a 2004 Elk
Management Plan, which also incorporates aspects of adaptive harvest
management.

Various management plans and programs have been developed statewide regarding
the management of CWD. The Montana Department of Livestock (DoL) is the
regulatory agency with jurisdiction over health issues and therefore control of CWD
on alternative livestock ranches (game farms) in Montana. As such, DoL has
promulgated regulations for alternative livestock regarding CWD testing and
movement of animals both interstate and intrastate. FWP is responsible for the
health of the free ranging wildlife populations in the state. Through its Wildlife
Disease Laboratory, MFWP has developed programs for diagnosis and surveillance
of wildlife diseases including a CWD surveillance program initiated in 1998. That
program is adapted on an annual basis as the status of CWD in surrounding states
changes, as new "high risk" areas within Montana are identified, and as the needs of
Montana's surveillance requirements change.

On a national level, a task force consisting of representatives from the United States
Department of Agriculture, the United States Department of the Interior, and from
state wildlife management agencies developed a "National Plan for Assisting States,
Federal Agencies, and Tribes in Managing Chronic Wasting Disease in Wild and
Captive Cervids" in 2002. In 2003, USDA/APHIS published proposed rules for
"CWD Herd Certification and Interstate Movement of Captive Deer and Elk." That
program is intended as a national program to help prevent the spread of CWD
within the captive cervid industry and the free ranging populations of cervids in the
U.S. Finally, the United States Fish and Wildlife Service (USFWS) distributed
"Chronic Wasting Disease Planning Guidelines for U.S. Fish and Wildlife Service
Lands" in February of 2004. That document guides the development of site-
specific plans for USFWS Regions and their field stations for surveillance and for
contingency response should CWD be found on-site.

The Montana CWD Action Plan will be developed using the advice and direction
provided by the national plans and in cooperation with other state and federal
agencies involved with the management of disease and wildlife populations.

1.8 Permits, Licenses, and Other Authorizations Required

Interagency cooperation and, more importantly, cooperation from private
landowners, will be required should CWD be found within Montana's borders.
Any actions taken on properties not controlled by FWP require that prior
authorization be obtained from the controlling entity. In some cases, actions may
be joint actions completed in cooperation with the controlling entity, whether state,
federal, or private. A list of the stakeholders from which authorization may be
required prior to initiating any actions include the following:

USFWS

NPS

USFS

BLM

Tribes

Private Landowners

1.9 Issues

1.9.1 Issues Studied in Detail

1.9.1.1 What is the potential effect of CWD on Montana's native deer and elk
populations?

The introduction of CWD into deer and elk populations in Montana will
likely effect population dynamics in the free ranging herds and ultimately
reduce overall populations or eliminate populations in affected areas over
time.

Indicators: The Adaptive Harvest Management Program in place through
the FWP Wildlife Division provides annual census data for deer and elk
populations throughout Montana. Although populations are effected by

10

many factors, a significant population decrease in a specific area as a result
of CWD could be quantified.

1.9.1.2 What is the potential effect of CWD on Wildlife Management Tools?

Management of big game populations, particularly deer and elk, in Montana
is accomplished through controlled harvest techniques using hunters as a
primary management tool. Recently, the Department has adopted the
Adaptive Harvest Management concept whereby intensive monitoring of
regional populations results in better quality population trend data that
indicate when to recommend appropriate hunting regulations (standard,
liberal, restrictive) to maintain desired population characteristics. Loss of
hunter numbers due to concerns about CWD would reduce the efficiency of
this very important management tool.

Indicators: Monitoring trends in the number of big game hunting licenses
sold in Montana will provide data on the effect of CWD on wildlife
management tools.

1.9.1.3 What is the potential effect of CWD on Montana's economy?

In 2001, approximately $250 million was spent on hunting in the state of
Montana. In addition, $350 million was spent by individuals interested in
wildlife viewing (USDI, Fish and Wildlife Services and U.S. Department of
Commerce, U.S. Census Bureau 2003). Montana's wildlife resources make
a significant contribution to the state's annual economy. Either real or
perceived disease problems in wildlife may result in a decrease in that
annual contribution that would be felt not only within the state governmental
agencies, but also within the business communities throughout Montana.
These negative financial impacts would especially impact regions within
CWD management areas or CWD "endemic" areas where CWD has been
detected and actions are ongoing.

Some states faced with the presence of CWD have established programs to
eradicate the disease. Other states have attempted to eliminate the disease
when it occurs in new locations within the state. These programs are costly
and are a burden to already stretched state wildlife management budgets.
Should control operations be needed in Montana, current state and federal
funding will be inadequate to finance the cost of the operations. Anticipated
costs for management actions planned in Wisconsin during 2003, which
included operations costs, disposal costs, and revenue loss due to anticipated
loss of hunters was in excess of $14.7 million. It becomes evident that
prevention of CWD is much more cost effective in protecting wildlife and
economic resources than management actions taken after CWD has been
found in a state.

11

Indicators: The number of hunter days is used annually to determine
hunting related expenditures in the state. National surveys are also used to
determine expenditures on wildlife viewing in Montana.

1.9.1.4 What is the public perception of the effect of CWD on human health?

The concept of an abnormal protein, or prion, causing a disease is novel.
Many diseases have now been attributed to prions, including variant
Creutzf el dt- Jakob disease (vCJD) in humans as well as CWD in deer and
elk. vCJD had killed over 150 humans worldwide as of June, 2005. vCJD
in humans has been linked to the ingestion of beef infected with bovine
spongiform encephalopathy (mad cow disease). Although the prion thought
to cause CWD has not been shown to affect humans, the perception of risk
due to the association between mad cow disease and vCJD has caused
public concern regarding CWD. Continued research on prion diseases will
expand our understanding of any potential risks to the human population
from CWD. All information regarding public health risks will be provided
to the public immediately with the cooperation of the Montana Department
of Public Health and Human Services as new information becomes
available.

Indicators: Surveys designed to monitor public perception on the effect of
CWD on human health.

1.9.1.5 What effect could CWD have on the captive, privately owned deer and
elk industry?

CWD is a disease of mule deer, white-tail deer, black-tail deer and elk and,
as such, may be transmitted freely from wild cervids to captive cervids and
vice versa. The alternative livestock industry in Montana was reported by
Montana Alternative Livestock Producers (MALP) to be a $20 million
industry in 2000. At that time, there were approximately 4,500 cervids
contained behind the high fences of approximately 80 alternative livestock
facilities. In situations where CWD has been detected in captive
populations, the standard action has been to kill and test all animals within
the fences for CWD. Although indemnity payments have been authorized
by USDA/APHIS, destruction of a privately owned herd may have
devastating financial impacts on individual alternative livestock ranchers.
Indemnity has been limited to 95% of the appraised value for an individual
animal with a cap of $3000 per animal. The appraised value is based on the
market value as determined by the meat or breeding value of the animal and
is fixed by an APHIS official appraiser and/or a State official appraiser.

CWD has had detrimental effects on the alternative livestock industry
nationwide through limitations on interstate movement of animals and
reductions in market value. Epidemiological studies have shown that the
sale and interstate movement of captive deer and elk has, in some cases at
least, been responsible for the appearance of CWD in spatially separated

12

geographical areas in the United States and Canada. Should CWD be found
in Montana, additional limitations on interstate movement of animals would
further affect Montana's alternative livestock industry. The alternative
livestock industry will play a key role in surveillance for and control of
CWD in Montana.

Indicators: Change of ownership and movement of alternative livestock is
reported by licensees to both FWP and the Department of Livestock. A
reduction in activity would be easily monitored as would an overall
reduction in the number of alternative livestock in the state.

1.9.1.6 How can CWD environmental contamination be reduced by the proper
disposal of waste from CWD infected animals?

Recent studies have verified that the prion protein may stay infective for up
to two and one half years in sites where shedding of the protein from
infected animals has occurred. In addition, the same studies have verified
that decomposed carcasses from CWD fatalities also have the ability to
transmit CWD after 2 years. Improper disposal of contaminated materials
may cause environmental contamination resulting in potential spread of the
disease. Studies are underway to determine the most effective methods for
environmental detection and for decontamination. Environmental
decontamination in large areas where CWD either is or has been present,
however, will be difficult.

Disposal of materials potentially contaminated with the CWD prion is a
significant issue. Waste materials may be generated from sample remnants
(heads) taken for the CWD surveillance program. Whole carcasses of either
road kill fatalities or collected as part of CWD management actions also
present disposal issues. The prion suspected of causing CWD may remain
"viable" for long periods of time and may not be inactivated or "destroyed"
by methods typically used for other pathogens. Methods used by various
states for proper disposal include high-temperature incineration, alkaline
hydrolysis tissue digestion, and disposal at municipal solid waste landfills.
The United States Environmental Protection Agency has prepared
"recommended interim practices for disposal of potentially contaminated
CWD carcasses and wastes." Those interim practices provide direction for
disposal of carcasses in a landfill area with management of leachate, daily
cover considerations, and compliance with 40CFR Part 258.

1.9.2 Issues Eliminated from Further Study

1.9.2.1 What is the effect of CWD and on domestic livestock?

White-tail deer, mule deer, black-tail deer, elk, and hybrids of those species
are susceptible to CWD. Studies evaluating natural transmission of CWD to

13

cattle, sheep, and a variety of other domestic species have indicated that
natural transmission of CWD to domestic livestock does not readily occur.
This issue will therefore not be evaluated in this document. Should natural
transmission of CWD to domestic species ever be demonstrated either under
laboratory or field conditions, however, the implications to the livestock
industry will radically affect current policies and action plans that attempt to
prevent, reduce, or eliminate CWD in the wild populations.

1.9.2.2 What is the effect of CWD on endangered species?

CWD has not been shown to be infective to species other than deer and elk.
Although there is no direct effect from CWD expected on any endangered
species, there may be indirect effects depending on the location where CWD
is found, management actions undertaken in that area, and any population of
endangered species found in that specific location. The indirect effects from
management actions may originate from the reduction in deer and/or elk in the
management zone if the endangered species is predatory and deer and/or elk
are a prey species. Because the location of any management action is
unknown at this time, an evaluation of the effects of a management action on
endangered species cannot be undertaken. If CWD is found in Montana, any
effects of a management action on endangered species in the immediate area
will be evaluated. It is thought that those effects would be minimal and would
be localized to the management area.

1.9.2.3 What is the effect of CWD on other government agencies?

The major impacts resulting from the discovery of CWD in Montana deer and
elk will be to MFWP. If the first finding of CWD is on land belonging to
other state or Federal agencies, there will be effects on those agencies. Initial
contacts have been made with most other state and government agencies and,
in many cases, they have been involved with the development of this plan.
Initially, cooperation from other state and federal agencies may involve
authorization to carry out management actions on the controlled lands. Some
agencies may potentially be directly involved in assisting with the
management actions. Ownership status of lands that may be affected in the
future by CWD is unknown. Once CWD is found in Montana, effects on
other government agencies will be evaluated in cooperation with any
government agency controlling land in the management zone. Until that
government agency is identified, however, it was not possible to assess the
impact on any particular agency.

14

Chapter 2: Alternatives

2.1 Introduction

The alternatives presented in Chapter 2 are the heart of this EA. Six alternatives were
selected for consideration. Each alternative is described in terms of plan objectives that
have been adapted from those recommended for inclusion in a CWD action plan by the
"Multi- state Guidelines for CWD Management in Free-Ranging White-tailed Deer, Mule
Deer and Elk." Those objectives include 1) prevention of CWD 2) surveillance for CWD
3) management of CWD 4) public information and communication and 5) research. The
most evident differences between the various alternatives may be found in the prevention
section and management section of each alternative description.

This chapter will summarize the predicted effects of each of the alternatives on the quality
of the relevant resources described in "Chapter 3 : Affected Environment." The chapter
will also evaluate how well each of the alternatives satisfies the objectives of the CWD
Action plan presented in Chapter 1. These comparisons and evaluations are intended to
provide a clear basis for choice among the alternatives. Comparisons regarding the
environmental effects of each of the alternatives will be expanded upon in "Chapter 4:
Environmental Consequences."

With the exception of the Alternative I, the "no action alternative," the management actions
described for each alternative will be influenced by the cervid species in which CWD is
detected, the habitat features of the surrounding area, any geologic or geographical barriers
that serve to discreetly separate distinct populations, and estimated population densities.
Without prior knowledge of these variables, only general actions can be described for each
alternative at this time.

2.2 Description of Alternatives

2.2.1 Alternative I: No Action Alternative

Under the no action alternative, the surveillance program currently in place to
monitor for the presence of CWD in Montana would be continued. No
additional preventative actions and no actions designed to eliminate or reduce
the incidence of CWD in Montana, if and when it is discovered, would be
planned.
2.2.1.1 Past Relevant Actions of Alternative I

• Prevention: MFWP's current approach for the prevention of CWD in
Montana would continue and would include the following programs:
Baiting and Feeding : Statutes regarding the baiting and feeding of
wildlife (MCA 87-3-1 30(c)) would remain unchanged and no additional
priority would be given to the enforcement of those statutes.
Translocation of Cervids : Laws prohibiting interstate and intrastate
translocation of deer fawns, elk calves and any other wild cervids would
be developed. These laws would prevent the movement of any wild
cervids to a central rehabilitation facility and therefore eliminate the
current rehabilitation program for orphaned deer fawns and elk calves.
Translocation of captive cervids is regulated by the Department of

15

Livestock and by a national program for the control and elimination of
CWD in captive cervids scheduled to be finalized in the fall of 2005.
Carcass Transport : MFWP would continue to recommend that heads
and spinal columns of deer and elk harvested by Montana hunters from out
of state areas where CWD is endemic be disposed of in the state of harvest
and not brought back into Montana.

Carcass Disposal : Montana Department of Environmental Quality
regulations state that "dead animals" may not be placed in or upon any
highway, road, street, or alley of this state; in or upon any public property,
highway, street, or alley under the control of the state of Montana or any
political subdivision thereof or any officer or agent or department thereof;
within 200 yards of such public highway, road, street, or alley or public
property; or on privately owned property where hunting, fishing, or other
recreation is permitted unless consent is obtained from the owner of the
property or his agent.

• Surveillance : Surveillance for CWD would continue in selected "high
risk" areas of Montana to monitor for the presence and/or prevalence of
CWD in Montana's cervid populations. Those high-risk areas have
currently been identified as MFWP administrative regions 5, 6, and 7 for
coverage in areas bordering Wyoming, South Dakota, and Saskatchewan.
Sample collections would be supplemented with road-killed animals and
"targeted samples" (animals displaying abnormal behavior or physical
debilitation). Sample numbers would be targeted to provide detection of
CWD at a 1% incidence at a 95% confidence interval. Surveillance for
CWD on alternative livestock ranches as regulated by the Montana
Department of Livestock would continue to require that any animal 16
months of age or older that dies be tested for CWD. A diagnosis of CWD
in any wild or captive deer or elk would result in the area being designated
a high-risk areas with mandatory sampling of harvested deer or elk
required for the next 5 years.

• Disease Management: No specific actions would be planned to manage
CWD if it appeared in Montana's wildlife populations.

• Public Information and Communication: The results of the
surveillance surveys would be reported to the public on an annual basis. A
public information plan developed by MFWP (Appendix 1) would be put
in place in the event that CWD were found in Montana.

• Research: An existing research study to evaluate demographics in two
populations of prairie mule deer in Southeastern Montana would be
continued as scheduled (Appendix 2).

2.2.2 Alternative II: Enhanced Surveillance

Under Alternative II, FWP would initiate activities to enhance surveillance
for the detection of CWD in Montana. No elaborate plans or multi-party
agreements would be developed for management of the disease should
CWD be found through the surveillance program. The preventative
measures employed in Alternative II are the same as those currently in place

16

and described in Alternative I, the No Action Alternative - that is they
remain as they have been in past years. Management of CWD will be
minimal and will involve adjustment of harvest quotas in affected areas to
decrease populations while providing additional samples to determine the
prevalence of CWD in the affected area. In Alternative II, MFWP proposes
a series of actions designed to enhance the surveillance program for CWD in
Montana.

2.2.2.1 Principal Actions of Alternative II

• Prevention : (as alternative I)

• Surveillance : Surveillance for CWD would be conducted statewide.
Hunter harvested samples would be collected at check stations at
appropriate locations in each FWP administrative region. Sample
collections would be supplemented with road-killed animals and "targeted
samples" (animals displaying abnormal behavior or physical debilitation).
The number of samples required would be determined based on the number
needed to detect a 1% incidence of CWD with a 99% confidence interval
within the defined population. Regional populations would be defined as
deer and elk living within the boundaries of each of the seven FWP
administrative regions and estimates made of numbers of animals within
those boundaries. These estimates would provide the basis for the number
of samples necessary to achieve the desired statistical significance.
Surveillance for CWD on alternative livestock ranches as regulated by the
Montana Department of Livestock would continue to require that any
animal 16 months of age or older that dies be tested for CWD. Any
diagnosis of CWD would result in designation as a high-risk area and
mandatory sampling of hunter harvested samples for the next 5 years.

• Disease Management : Increases in harvest quotas during established big
game seasons would be used to reduce population densities in affected areas
if CWD were detected. CWD sampling of harvested animals would be
mandatory from any affected area. In addition, the removal of whole heads
and/or spinal columns from animals harvested in the management area
would be prohibited. The affected area would be determined based on
existing population data and geographic/geologic barriers that restrict
movement of the population in that affected area.

• Public Information & Communication In the event that CWD were found
in Montana's wildlife populations, the draft CWD public information plan
(Appendix 1) would be put in place to keep the public informed of all
findings concerning prevalence and distribution of CWD in the deer and elk
populations and to inform the public of all latest information concerning the
disease itself.

• Research: Overall effectiveness of the management strategy would be
evaluated based on annual CWD prevalence data in the affected area. The
effect of the management action on the total population would be evaluated
using population estimates obtained through aerial surveys and survivorship
determined from radio marked animals. Aspects of disease ecology,

17

including changes in population size, density, distribution, age structure,
sexual bias for CWD prevalence, and disease related mortality would be
monitored.

2.2.3 Alternative III (Enhanced Prevention and Containment)

Alternative III would enhance efforts for the prevention of CWD in Montana
and establish "buffer zones" to contain the spread of CWD to other
populations in Montana or beyond Montana's borders. Containment
methods would be heavily dependent upon geologic/geographic aspects of
the affected area as for the development of habitat modification methods to
create a containment buffer.
2.2.3.1 Principal Actions of Alternative III

• Prevention : Alternative III would focus on efforts to prevent the
"introduction" of CWD into Montana. These efforts would include:
Baiting and Feeding: Current laws preventing baiting and feeding of
game animals would be revised through legislative procedure to provide
for easier interpretation and more effective prosecution/deterrent ability.
Translocation of Cervids: Laws prohibiting interstate and intrastate
translocation of deer fawns, elk calves and any other wild cervids would
be developed. These laws would prevent the movement of any wild
cervids to a central rehabilitation facility and therefore eliminate the
current rehabilitation program for orphaned deer fawns and elk calves.
The DoL would conduct a risk assessment concerning any requests for
importation or movement of captive cervids into or within Montana. Only
movements of captive cervids identified by DoL as low risk for
transmitting CWD would be authorized for importation or would be
allowed to move from one alternative livestock facility to another within
Montana.

Carcass Transport: Laws and/or regulations concerning carcass
transport would be developed through appropriate legislative procedure or
MFWP commission rules. These laws/regulations would prohibit the
import of certain cervid carcass parts (whole heads or spinal columns) of
animals harvested from states and/or areas of states experiencing CWD in
wild populations. Carcass parts allowed for importation would include:

1 . Meat that is cut and wrapped

2. Quarters or other portions of meat with no part of the spinal column
or head attached.

3 . Meat that has been boned out.

4. Hides with no heads attached

5. Clean (no meat or tissue attached) skull plates with antlers attached

6. Antlers with no meat or tissue attached

7. Upper canine teeth, also known as "buglers", "whistlers" or "ivories"

8. Finished head, partial body or whole body mounts already prepared
by a taxidermist.

Carcass Disposal: Laws and/or regulations concerning disposal of heads,
spinal cords, and remains of harvested cervids would be developed

through appropriate legislative procedures. These laws would require
appropriate disposal of carcasses and carcass parts in Class II municipal
solid waste landfills. Meat processors, taxidermists, and others normally
involved with the disposal of carcass parts would be contacted through
mailings to inform them of disposal requirements. Contaminated
carcasses or heads and spinal cords from disease management areas would
be disposed of through incineration at the management site.
Surveillance : Monitoring for CWD would be continued in areas
designated as high-risk areas. Those high-risk areas currently include
MFWP administrative regions 5,6, and 7, that border Wyoming, South
Dakota, and Saskatchewan. Sample collections would be supplemented
with road-killed animals and "targeted samples" (animals displaying
abnormal behavior or physical debilitation). The discovery of CWD in
Montana or in new areas of adjacent states would result in the
identification of new high-risk areas. The program for collection of road-
kill samples for CWD testing would be expanded to provide state
coverage on a limited number of samples. "Regionally intensive"
surveillance would occur in the CWD management zones. Surveillance
for CWD on alternative livestock ranches as regulated by the Montana
Department of Livestock would continue to require that any animal 16
months of age or older that dies be tested for CWD. Any diagnosis of
CWD in deer or elk would result in designating surrounding areas as high-
risk areas with mandatory CWD sampling of harvested animals for 5
years.

Disease Management: Buffer zones would be established around a
management zone to keep potentially affected cervids within the
management zone boundaries and restrict movement of cervids into the
zone. Buffers would be established depending on local geographic or
geologic features and known movement patterns of cervids. In addition,
harvest quota adjustments in surrounding areas could be used to establish
buffer areas. CWD sampling of any animals harvested within the buffer
zone or the management zone would be mandatory. In addition, the
removal of the whole heads and/or spinal columns from animals harvested
in the management area would be prohibited. All harvested animals
would be sampled for CWD and results supplied to the tag holder. Any
animals harvested by department personnel would be held until the CWD
testing results were available. Animals with no evidence of CWD that are
harvested by department personnel would be provided to food banks while
CWD positive carcasses would be incinerated.

Public Information & Communication In the event that CWD were
found in Montana's wildlife populations, the draft CWD public
information plan (Appendix 1) would be put in place to keep the public
informed of all findings concerning prevalence and distribution of CWD
in the wildlife populations and to inform the public of all latest scientific
information relating to CWD.

19

• Research : Overall effectiveness of the management strategy would be
evaluated based on annual prevalence data in the effected area. The effect
of the management action on the total population would be evaluated
using population estimates obtained through aerial surveys. Aspects of
disease ecology, including changes in population age structure, sexual bias
for CWD prevalence, disease related mortality, and changes in predator
populations and behavior would be monitored.

2.2.4 Alternative IV (Control at 1%)

Alternative IV would strengthen CWD prevention policies through changes
in baiting and feeding laws and through the development of policies or
educational programs concerning carcass transport, cervid translocation, and
carcass disposal. Surveillance activities would be moderately enhanced
above current activities with intensive sampling in affected areas
(management zones) and statewide sampling of road-kill fatalities. Disease
management programs would first determine population boundaries of
affected populations prior to intensive and continued sampling exercises
until a prevalence of < 1% CWD positive animals was detected in a
statistical sample.
2.2.4.1 Principal Actions of Alternative IV

• Prevention

Baiting and Feeding: Current laws preventing baiting and feeding of
game animals would be revised through legislative channels to provide for
easier interpretation and more effective prosecution/deterrent ability.
Translocation of Cervids: The translocation of all wild cervids intrastate
and interstate would be prohibited through policy. This policy would
curtail the current practice of rehabilitation of orphan fawns and elk calves
at a centralized Wildlife Center in Helena. The DoL would conduct a risk
assessment concerning any requests for importation or movement of
captive cervids within or into Montana. Only movements of captive
cervids identified by DoL as being of low risk for transmitting CWD
would be authorized for importation or for movement within Montana.
Carcass Transport: An education program for hunters would be
developed stressing the potential impacts of bringing heads and spinal
cords of cervids back to Montana from states or areas of states where
CWD has been detected. Montana hunters successful in obtaining big
game licenses from states with active CWD in free ranging populations
would be contacted by mail. Those hunters would receive strong
recommendations from the Department concerning the proper disposal of
heads and spinal cords and be advised not to bring those carcass parts back
into Montana.

Carcass Disposal: Appropriate conditions for disposal of all harvested
heads, spinal cords, and remains from cervids would be communicated to
the public through a media and educational campaign. Again, those
methods involve the disposal of carcasses or carcass parts in a Class II
municipal solid waste landfill. Contaminated carcasses or heads and

20

spinal cords from disease management areas would be disposed of through
incineration at the management site

Surveillance: Under alternative IV, surveillance would continue to be
focused on designated high-risk areas. The program for collection of road-
kill samples for CWD testing would be expanded to provide statewide
coverage on a limited basis. Sample collections would be supplemented
with "targeted samples" (animals displaying abnormal behavior or
physical debilitation). "Regionally intensive" surveillance would be
conducted in the management zone with CWD sampling mandatory for all
animals harvested within the zone. Surveillance for CWD on alternative
livestock ranches as regulated by the Montana Department of Livestock
would continue to require that any animal 16 months of age or older that
dies be tested for CWD. A diagnosis of CWD in deer or elk would result
in the designation of surrounding areas as high-risk areas with mandatory
sampling of harvested deer or elk for the next 5 years.
Disease Management Upon initial diagnosis, 50 cervids from the
immediate area would be radio collared. Tonsil biopsies or other
acceptable live animal tests for the diagnosis of CWD would be conducted
on each collared animal. If any radio collared animals were CWD
positive, they would be removed from the population. The movements of
radio-collared animals would be monitored with telemetry for 5 months to
12 months to determine population boundaries. Using population
estimates within the determined population boundaries, a sample of
animals of adequate number to enable detection of a 1% incidence of
CWD at a 99% confidence interval would be collected. If CWD were
found at >1%, another statistical sample would be obtained for testing by
killing additional animals and this process continued until the result
obtained was <1% incidence. Upon reaching a disease incidence of <1%,
the area would be designated as a "high risk" area and mandatory
sampling of hunter harvested animals conducted for 5 years. A >1%
incidence of CWD in the annual sample would initiate another statistical
sampling as described earlier. If at any time during the sampling process,
a CWD prevalence of >5% were detected in the sample, immediate
population reduction activities would be initiated in an attempt to reduce
the estimated population by 50%. All harvested animals would be
sampled for CWD and results supplied to the tag holder. Any animals
harvested by department personnel would be held until the CWD testing
results were available. Animals with no evidence of CWD that are
harvested by department personnel would be provided to food banks while
CWD positive carcasses would be incinerated.

Movement of harvested carcasses or carcass parts out of the management
zone would be limited to:

1 . Meat that is cut and wrapped

2. Quarters or other portions of meat with no part of the spinal column
or head attached.

21

3 . Meat that has been boned out.

4. Hides with no heads attached

5. Clean (no meat or tissue attached) skull plates with antlers attached

6. Antlers with no meat or tissue attached

7. Upper canine teeth, also known as "buglers", "whistlers" or "ivories"

8. Finished head, partial body or whole body mounts already prepared
by a taxidermist.

• Public Information & Communication: The results of the surveillance
surveys would be reported to the public following compilation of results
on an annual basis. A public information plan developed by MFWP
(Appendix 1) would be put in place in the event that CWD were found in
Montana.

• Research : Overall effectiveness of the management strategy would be
evaluated based on annual prevalence data in the effected area. The effect
of the management action on the total population would be evaluated
using population estimates obtained through aerial surveys and utilizing
the radio-collared sample. Aspects of disease ecology, including changes
in population age structure, sexual bias for CWD prevalence, disease
related mortality, and changes in predator populations and behavior would
be monitored.

2.2.5 Alternative V (Control at 0%)

Alternative V employs a more aggressive program for the prevention of
CWD than Alternative IV in that it proposes the development of laws
focused on the preventative aspects. Alternative V also takes a more
aggressive management position in that once an affected population is
discovered, that population is sampled through collection of samples from
elk and/or deer in a series of sampling efforts until no CWD is detected in
the sample taken.
2.2.5.1 Principal Actions of Alternative V

• Prevention

Baiting and Feeding: Current laws preventing baiting and feeding of
game animals would be revised through the legislative process to provide
for easier interpretation and more effective prosecution/deterrent ability.
Translocation of Cervids: Laws prohibiting the translocation of wild
cervids would be developed through legislative procedures. These laws
would curtail the current practice of rehabilitation of orphan deer fawns
and elk calves at the Wildlife Center in Helena as well as any translocation
of wild cervids in Montana. The DoL would conduct a risk assessment
concerning any requests for importation or movement of captive cervids
within or into Montana. Only movements of captive cervids identified by
DoL as being of low risk for transmitting CWD would be authorized for
importation or for movement within Montana.
Carcass Transport: Laws and/or regulations concerning carcass
transport would be developed through appropriate legislative procedure or
through MFWP commission rules. These laws/regulations would prohibit

22

the import of carcasses from states and/or areas of states experiencing
CWD in wild populations and would be enforced by MFWP. The only
carcass parts allowed into Montana from states where CWD has been
diagnosed would be:

1 . Meat that is cut and wrapped

2. Quarters or other portions of meat with no part of the spinal column or
head attached.

3 . Meat that has been boned out.

4. Hides with no heads attached

5. Clean (no meat or tissue attached) skull plates with antlers attached

6. Antlers with no meat or tissue attached

7. Upper canine teeth, also known as "buglers", "whistlers" or "ivories"

8. Finished head, partial body or whole body mounts already prepared by
a taxidermist.

Carcass Disposal: Regulations would be developed either through the
legislative procedure or through Commission Rule concerning disposal of
heads and spinal cords. Those regulations would require disposal of
carcass parts in municipal Class II municipal solid waste landfills and
would provide penalties for those not complying with the regulations.
Contaminated carcasses or heads and spinal cords from disease
management areas would be disposed of through incineration.
Surveillance Surveillance in designated high-risk areas would continue,
but the collection of road-kill samples would be expanded to provide for
statewide coverage. Sample collections would be supplemented with
"targeted samples" (animals displaying abnormal behavior or physical
debilitation). "Regionally intensive" surveillance in the management
zones would be initiated along with the management actions. Surveillance
for CWD on alternative livestock ranches as regulated by the Montana
Department of Livestock would continue to require that any animal 16
months of age or older that dies be tested for CWD. The diagnosis of
CWD in any elk or deer would result in surrounding areas being
designated a high-risk with mandatory sampling of harvested animals for
the next 5 years.

Disease Management Upon initial diagnosis, 50 cervids from the
immediate area would be radio collared. Tonsil biopsies or other
acceptable live animal tests for the diagnosis of CWD would be conducted
on each collared animal. If any radio collared animals were CWD
positive, they would be removed from the population. The movements of
radio-collared animals would be monitored with telemetry for 5 months to
12 months to determine population boundaries. Using population
estimates within the determined population boundaries, a sample of
adequate size to enable detection of a 1% incidence of CWD at a 99%
confidence interval would be collected. If any CWD positive animals
were found in that sample, another statistical sample would be obtained
for testing and this process continued until the result obtained was 0%
incidence. Upon reaching a disease incidence of 0%, the area would be

23

designated as a "high risk" area and mandatory sampling of hunter
harvested animals required for 5 years. Any detection of CWD in the
annual sample would initiate another statistical sampling as described
earlier. If at any time during the sampling process, a CWD prevalence of
>5% were detected in the sample, immediate population reduction
activities would be initiated in an attempt to reduce the estimated
population by 50%. All harvested animals would be sampled for CWD
and results supplied to the tag holder. Any animals harvested by
department personnel would be held until the CWD testing results were
available. Animals with no evidence of CWD that are harvested by
department personnel would be provided to food banks while CWD
positive carcasses would be incinerated.

Movement of harvested carcasses or carcass parts out of the management
zone would be limited to those parts allowed under carcass transport
requirements above. Heads and spinal cords would not be allowed out of
the management zone.

• Public Information & Communication The results of the surveillance
surveys would be reported to the public following compilation of results
on an annual basis. A public information plan developed by MFWP
(Appendix 1) would be put in place in the event that CWD were found in
Montana.

• Research: Overall effectiveness of the management strategy would be
evaluated based on annual prevalence data in the effected area. The effect
of the management action on the total population would be evaluated
using population estimates obtained through aerial surveys. Aspects of
disease ecology, including changes in population size, density,
distribution, age structure, sexual bias for CWD prevalence, and disease
related mortality would be monitored. Re-colonization of the area by non-
local cervids following sampling or depopulation efforts would be
monitored.

2.2.6 Alternative VI (Aggressive Elimination) Similar to actions taken in
Wisconsin following the finding of CWD in 2002, Alternative VI calls for an
aggressive elimination of animals within a pre-determined "eradication
zone". Alternative VI also provides an aggressive strategy in the
development of laws anticipated to aid in the prevention of CWD in
Montana. Finally, the surveillance program is expanded in Alternative VI to
statistically sample the entire state for the presence of CWD.
2.2.6.1 Principal actions of Alternative VI
Prevention

Baiting and Feeding: Current laws preventing baiting and feeding of
game animals would be revised through the legislative process to
provide for easier interpretation and more effective prosecution/deterrent
ability.

24

Translocation of Cervids: Laws prohibiting the translocation of wild
cervids would be developed through legislative procedures. These laws
would curtail the current practice of rehabilitation of orphan deer fawns
and elk calves at the Wildlife Center in Helena as well as any translocation
of wild cervids in Montana. The DoL would conduct a risk assessment
concerning any requests for importation or movement of captive cervids
within or into Montana. Only movements of captive cervids identified by
DoL as being of low risk for transmitting CWD would be authorized for
importation or for movement within Montana.
Carcass Transport: Laws and/or regulations concerning carcass
transport would be developed through appropriate legislative procedure or
through MFWP commission rules. These laws/regulations would prohibit
the import of carcasses from states and/or areas of states experiencing
CWD in wild populations and would be enforced by MFWP. The only
carcass parts allowed into Montana from states where CWD has been
diagnosed would be:

1 . Meat that is cut and wrapped

2. Quarters or other portions of meat with no part of the spinal column
or head attached.

3 . Meat that has been boned out.

4. Hides with no heads attached

5. Clean (no meat or tissue attached) skull plates with antlers attached

6. Antlers with no meat or tissue attached

7. Upper canine teeth, also known as "buglers", "whistlers" or
"ivories"

8. Finished head, partial body or whole body mounts already prepared
by a taxidermist.

Carcass Disposal: Regulations would be developed either through the
legislative procedure or through Commission rule concerning disposal of
heads and spinal cords. Those regulations would require disposal of
carcass parts in municipal Class II municipal solid waste landfills and
would provide penalties for those not complying with the regulations.
Contaminated carcasses or heads and spinal cords from disease
management areas would be disposed of through incineration at the
management site

Surveillance: Surveillance for CWD would be conducted on a statewide
level. Hunter harvested samples would be collected at appropriately
located check stations in each FWP administrative region. Sample
collections would be supplemented with road killed animals and "targeted
samples" consisting of animals reported to FWP as being sick or acting
strangely. The number of samples collected would be determined based
on the number needed to provide detection of a 1% incidence of CWD
with a 99% confidence interval within a defined population. Separate
populations would be defined as animals living within the boundaries of
each FWP administrative region and estimates made of numbers on
animals within those boundaries. Surveillance for CWD on alternative

25

livestock ranches as regulated by the Montana Department of Livestock
would continue to require that any animal 16 months of age or older that
dies be tested for CWD. A diagnosis of CWD in any deer or elk would
result in surrounding areas being designated high-risk areas with
mandatory sampling of harvested deer or elk required for the next 5 years.

• Disease Management Following the initial detection of CWD,
population "boundaries" of the local cervid population would be
estimated using available data. At a minimum, a 5-mile radius would be
established from the index case and animals within that 5 miles radius
(approximately 80 square miles) eradicated to the extent possible.
Eradication would be carried out through the use of hunter incentives
during established big game seasons and/or through harvest by department
personnel. All harvested animals would be sampled for CWD and results
supplied to the tag holder. Any animals harvested by department
personnel would be held until the CWD testing results were available.
Animals with no evidence of CWD that are harvested by department
personnel would be provided to food banks while CWD positive carcasses
would be incinerated.

• Public Information & Communication The results of the surveillance
surveys would be reported to the public following compilation of results
on an annual basis. A public information plan developed by MFWP
(Appendix 1) would be put in place in the event that CWD were found in
Montana.

• Research Evaluate the effectiveness of strategy based on sample data
collected in areas bordering the management zone following elimination
of the affected population. Monitor re-colonization of the area by radio-
collaring and tracking 50 animals from outside the eradication zone.
Evaluate disease prevalence data in the affected area based on age
structure and sexual bias for positive animals.

2.3 Process Used to Develop the Alternatives

Initially, CWD was a regional disease affecting only areas of Colorado and
Wyoming. Following the discovery of CWD in the game farm industry in 1996 and
the spread of CWD to wildlife and captive cervids in other locations throughout the
United States, states and provinces hurried to install management plans in the face
of disease activity. National plans have provided guidance for control of CWD
both in the captive cervid industry as well as for wildlife management programs
dealing with free ranging populations of cervids. While the success of these
programs is unknown regarding reduction or elimination of the disease in either
captive or free ranging cervids, it is well accepted that early actions both to prevent
the introduction of CWD and to eradicate initial "hot spots" provide the best chance
for success in any program.

Alternatives evaluated for Montana's CWD Action Plan were generated through
scoping meetings where issues were identified and developed, through input from
the CWD Action Plan Oversight Committee, through input from other agencies and

26

organizations, and through guidance from existing statutes and regulations. CWD
has been diagnosed on one alternative livestock ranch in Montana, but has not yet
been diagnosed in the free ranging deer or elk populations. This fact has directed
the development of alternatives that stress the preventative aspect of the program
and that, in some cases, aggressively "attack" any initial diagnosis of CWD in
Montana. An efficient sampling program is also present in each alternative to
facilitate the early discovery of CWD and to evaluate its prevalence. Population
reduction strategies, found in some of the alternatives, are intended to prevent the
spread of the disease and perhaps completely eliminate the disease.

One of the main objectives of this document is to provide public information and to
educate the general public and the hunting public concerning CWD. That
knowledge should help the public to understand the potential impacts of finding
CWD in Montana's wildlife populations and why particular actions are being
considered. The potential success of any of the proposed alternatives for the
prevention and management of CWD is unknown. Periodic review of the selected
management plan by a state CWD Management Team to determine management
success or failure as well as to evaluate any new information concerning success or
failure of plans in use by other states will allow for modification of any selected
alternatives on an annual basis.

In evaluating potential environmental effects, the no action alternative has fewer
significant environmental effects that may be seen in the immediate future than any
of the other alternatives. To take no action in the fight against CWD could,
however, have the most significant environmental effects in the long term through
eventual reduction of overall herd health and of big game populations that could be
permanent.

The public must be advised that although the best scientific information possible
has been used to make presumptions concerning the short and long term
environmental effects of CWD on the human environment, many of the conclusions
are conjecture. Again, the adaptive nature the selected alternative will provide for
changes to the plan on an annual basis as the body of scientific knowledge
concerning CWD evolves.

2.4 Summary Comparison of the Activities of Each Alternative, Predicted
Achievement of Objectives, and Predicted Environmental Effects on Issue
Resources. Tables, 2.4.1, 2.4.2, and 2.4.3 provide a comparative summarization of
the alternatives presented in this chapter. Comparisons are made of what types of
activities each alternative suggests (Table 2.4.1), how each alternative fulfills the
objectives of a CWD Action program discussed in section 1.4 (Table 2.4.2), and
what the predicted environmental impacts of each alternative are (Table 2.4.3).

27

2.4.1 Table 1:

Summary Comparison of the Activities of Each Alternative

Prevention

Surveillance

Management

Public Info

Research

Alternative
I

(no action)

No changes in baiting and feeding
enforcement, wildlife rehab.,
carcass transport, or carcass
disposal requirements

Surveillance in identified
high-risk areas. Continued
alternative livestock 16 month
testing requirement.

No management actions
developed

Report annual CWD
surveillance reports.
Public info plan for
keeping public up to
date on status of disease
in Montana.

SE Montana study
continued for prairie
mule deer
demographics.

Alternative
II

(Enhanced
Surveillance)

As alternative I

Statewide surveillance of
hunter, road kill, and targeted
by administrative region.
Goal of 1% detection at 99%
CI. Continued alternative
livestock 16 month testing
requirement

Adjust harvest quotas to reduce
populations in "affected areas."
Mandatory sampling from
affected areas. Affected area
boundary based on geographic
or geologic barriers limiting
population movement.

As alternative I.

Continue SE
Montana study.
Evaluate disease
ecology in affected
area.

Alternative
III

(Enhanced
Containment
& Prevention)

Revise baiting and feeding laws;
develop laws prohibiting
movement of cervids, no
rehabilitation of orphan
fawns/calves; new laws on carcass
transport and carcass disposal

Surveillance in high-risk
areas. Enhance road kill
collection for statewide
coverage. Maintain targeted
sample collection.
Surveillance in CWD
management zones.
Continued alternative
livestock 16 month testing
requirement

Develop buffer zones around
affected areas to decrease
immigration and emigration of
cervids.

As alternative I

Monitor effectiveness
of buffer, prevalence
of CWD within and
around management
area, and effect of
action on population.

28

2.4.1 Summary Comparison of the Activities of Each Alternative (cont.)

Prevention

Surveillance

Management

Public Info

Research

Alternative
IV

(Control at
1%)

Revise baiting and feeding laws;
no rehabilitation of fawns/calves;
educate hunters on carcass
transport and carcass disposal.

Surveillance in high-risk
areas. Enhance road-kill for
statewide coverage.
Regionally intensive
surveillance in management
areas. Continued alternative
livestock 16 month testing
requirement

Radio collar and tonsil test 50
deer. Delineate population.
Sample for 1% detection 99%
CI. If <1%, surveillance as
"high risk" next year. If >1%
take second sample and continue
until <1%. If find >5% initiate
50% population reduction.

As alternative I

Effectiveness of
strategy per
prevalence data.
Monitor effect of the
action on population.
Evaluate disease
ecology. Monitor re-
colonization of area.

Alternative

V

(Control at

0%))

Maximize baiting and feeding
laws; new laws on translocation
(no rehabilitation); regulations on
carcass transport and disposal.

Surveillance in high-risk
areas. Enhance road-kill for
statewide coverage.
Regionally intensive
surveillance in management
areas. Continued alternative
livestock 16 month testing
requirement

Radio collar and tonsil test 50
deer. Delineate population.
Sample for 1% detection 95%
CI. No positives then annual
surveillance as "high risk." If
any positive continue with
additional samples until no
positives detected. If find >5%
initiate 50% population
reduction.

As alternative I

Effectiveness of
strategy per
prevalence data.
Monitor effect of the
action on population.
Evaluate disease
ecology. Monitor re-
colonization of area.

Alternative
VI

(Aggressive
Elimination))

Maximize baiting and feeding
laws; new laws on translocation
(no rehabilitation); regulations on
carcass transport and disposal.

Statewide surveillance of
hunter, road-kill, and targeted
by administrative region.
Goal of 1% detection at 99%
CI. Continued alternative
livestock 16 month testing
requirement

Eradication zone developed with
goal of elimination of cervids
within that zone.

As alternative I

Sample areas
bordering eradication
zone for effectiveness
of strategy. Monitor
re-colonization.
Disease ecology
studies.

29

2.4.2 Table 2:

Summary Comparison of the Achievement of Project Objectives

Alternative I
(No Action)

Alternative II

(Enhanced

surveillance)

Alternative III
(Containment &
Prevention)

Alternative IV
(Control at 1%)

Alternative V
(Control at 0%)

Alternative VI

(Aggressive

Elimination)

Objective #1
Prevent

Introduction of
CWD

Carcass transport,
baiting & feeding,
improper disposal
of carcasses, and
translocation of
cervids all have the
capacity to bring
the first case of
CWD mto
Montana

Carcass transport,
baiting & feeding,
improper disposal
of carcasses, and
translocation of
cervids all have the
capacity to bring
the first case of
CWD mto
Montana

Development of
laws controlling
transport, baiting &
feeding, proper
disposal, and
translocation
should slow or
prevent the
appearance of
CWD in Montana

Development of
laws and
educational
programs for CWD
prevention may
prove more
effective than the
development of
laws that may be
difficult to enforce.

Development of
laws controlling
transport, baiting &
feeding, proper
disposal, and
translocation
should slow the
appearance of
CWD in Montana

Development of
laws controlling
transport, baiting
& feeding, proper
disposal, and
translocation
should slow the
appearance of
CWD in Montana

Objective #2
Minimize Spread
of CWD

No management
actions taken to
minimize spread

Reduction in
population
densities through
quota adjustment
may slow the
spread of CWD

An effective buffer
zone and
preventative
measures would
limit spread

Density reductions
in management
zone and
preventative
measures would
limit spread

Density reductions
in management
zone and
preventative
measures would
limit spread

Elimination of
affected

population and
preventative
measures would
spread

Objective #3
Provide Timely
Information to
Public

Information plan
developed by
Conservation
Education Division

Information plan
developed by
Conservation
Education Division

Information plan
developed by
Conservation
Education Division

Information plan
developed by
Conservation
Education Division

Information plan
developed by
Conservation
Education Division

Information plan
developed by
Conservation
Education
Division

Objective #4
Maintain Adaptive
CWD Surveillance

Surveillance in
areas as being of
high risk for CWD

Surveillance state-
wide with 99% CI
of detection @ 1%

Surveillance in
high risk areas -
road-kill for
statewide

Surveillance in
high risk areas -
road-kill for
statewide

Surveillance in
high risk areas -
road-kill for
statewide

Surveillance state-
wide with 99% CI
of detection @
1%-

30

2.4.3 Table 3:

Summary Comparison of Predicted Environmental Effects

Effect of CWD on
Montana's native
deer and elk

populations?

What is the effect of
CWD on wildlife
management tools?

What is the effect of
CWD on Montana's
economy

What is the effect
on the public
perception of CWD
on human health?

Effect of CWD on
the captive, privately
owned deer and elk
industry?

What is the effect
on disposal of
CWD infected

animals on

environmental
contamination?

Alternative
(No Action)

With only current
prevention strategies
and no intervention,
CWD may occur
sooner in Montana.
Effects forecasted by
models indicate
significant population
reductions within 30-
50 years.

If CWD does not occur in
Montana, no effect. If
CWD is found and
prevalence increases,

hunter participation can
be expected to decline.

Local effects due to
reduction in hunter
numbers, which

would become

generalized statewide
if CWD spread to
new areas.

Providing current
and scientifically
sound information
will allow

informed public
decisions and

perceptions
concerning CWD.

Shipment of cervids
out of state may be
inhibited and some
facilities could be
quarantined and/or
depopulated.
Potential needs for
double fencing in
affected area.

No requirements in
place for disposal
of infected animals
or parts of infected
animals. This

could lead to an
increased potential
for the spread of
CWD in Montana.

Alternative
(Enhanced
Surveillance)

II

Timely intervention
by quota adjustment
may slow the spread
of CWD or eradicate
CWD. Population
effects could be
limited to local
population reductions
unless CWD spreads
to other areas.

More surveillance data
may influence hunters
hunt in "CWD free"
areas. Hunter numbers in
affected areas may
decline depending on
prevalence of CWD in the
population.

Increased quotas for
management may
benefit local

economies if hunters
respond. If CWD
becomes established,
however, locally

negative effect

through loss of hunter
numbers.

Providing current
and scientifically
sound information
will allow

informed public
decisions and

perceptions
concerning CWD.

Shipment of cervids
out of state may be
inhibited and some
facilities could be
quarantined and/or
depopulated.
Potential needs for
double fencing in
affected area.

No requirements in
place for disposal
of infected animals
or parts of infected
animals. This

could lead

increased potential
for the spread of
CWD in Montana.

31

2.4.3 Summary Comparison of Predicted Environmental Effects (continued)

Effect of CWD on
Montana's native
deer and elk

populations?

What is the effect of
CWD on wildlife
management tools?

What is the effect of
CWD on Montana's
economy

What is the effect
on the public
perception of CWD
on human health?

Effect of CWD on
the captive, privately
owned deer and elk
industry?

What is the effect
on disposal of

CWD
animals.

infected

Alternative III
(Enhanced
Containment
and Prevention)

If containment can be
achieved, the effects
would be on the local
population only.

Prevention may slow
appearance of CWD
inMT.

Buffer zones may require
high hunting pressures in
areas surrounding
management zone.
Hunter incentives may be
necessary to provide
required numbers. Less
desire to hunt in affected
area anticipated.

Local effects through
reduction of hunter
numbers. May be
overcome by
continuous efforts to
maintain buffer zone
that will provide
income to the local
community.

Providing current
and scientifically
sound information
will allow

informed public
decisions and

perceptions
concerning CWD.

Shipment of cervids
out of state may be
inhibited and some
facilities could be
quarantined and/or
depopulated.
Potential needs for
double fencing in
affected area.

Laws prohibiting
improper disposal
will aid in the
prevention of

environmental
contamination and
reduce potential for
spread of CWD.

Alternative IV
(Control at 1%)

Reduction of the
local cervid

population would
occur through

continual monitoring
of defined local area
until <1% prevalence
detected. Prevention
aspects provide

statewide protection
of cervid population.

May see reduction in
hunter numbers in
affected area(s). May
need incentives to provide
required hunter numbers
for management. If

management goals

attained, should not
significantly affect

statewide hunter interest.

Local effects through
reduction of hunter
numbers over time
and short-term loss of
animal numbers. If
successful in

elimination, long-
term beneficial
effects statewide.

Providing current
and scientifically
sound information
will allow

informed public
decisions and

perceptions
concerning CWD.

Shipment of cervids
out of state may be
inhibited and some
facilities could be
quarantined and/or
depopulated.
Potential needs for
double fencing in
affected area.

Educational
programs for

carcass transport
and disposal are
expected to aid in
prevention of

environmental
contamination and
reduce the potential
for spread of
CWD.

32

2.4.3 Summary Comparison of Predicted Environmental Effects (continued)

Effect of CWD on
Montana's native
deer and elk

populations?

What is the effect of
CWD on wildlife
management tools?

What is the effect of
CWD on Montana's
economy

What is the effect
on the public
perception of CWD
on human health?

Effect of CWD on
the captive, privately
owned deer and elk
industry?

What is the effect
on disposal of
CWD infected

animals.

Alternative V
(Control at 0%)

Aggressive reduction
to achieve 0%
detection more likely
than Alternative IV to
have significant
effect on local
population. If CWD
controlled, protective
effect on statewide
population.

May see reduction in
hunter numbers in
affected area(s). May
need incentives to provide
required hunter numbers
for management. If

management goals

attained, should not
significantly affect

statewide hunter interest.

Local effects through
reduction of hunter
numbers over time
and short-term loss of
animal numbers. If
successful in

elimination,
beneficial effects

statewide.

Providing current
and scientifically
sound information
will allow

informed public
decisions and

perceptions
concerning CWD.

Shipment of cervids
out of state may be
inhibited and some
facilities could be
quarantined and/or
depopulated.
Potential needs for
double fencing in
affected area.

Laws prohibiting
improper disposal
will aid in the
prevention of

environmental
contamination.

Alternative VI

(Aggressive

Elimination)

Significant effect on
local population. If
successful in

eliminating CWD,
protective effect on
statewide population.

Eventual loss of hunters
in immediate area due to
lack of game. May need
incentives initially to
provide required hunter
numbers. If management
goals attained, should not
significantly affect

statewide hunter interest.

Local effects through
reduction of hunter
numbers over time
and short-term loss of
animal numbers. If
successful in

elimination,
beneficial effects

statewide.

Providing current
and scientifically
sound information
will allow

informed public
decisions and

perceptions
concerning CWD.

Shipment of cervids
out of state may be
inhibited and some
facilities could be
quarantined and/or
depopulated.
Potential needs for
double fencing in
affected area.

Laws prohibiting
improper disposal
will aid in the
prevention of

environmental
contamination.

33

Chapter 3: Affected Environment

3.1 Introduction

Chapter 3: This section describes the existing conditions of the environmental resources
in Montana that could be affected by implementing any of the alternatives presented in
Chapter 2. The description of the existing environment in Chapter 3, combined with the
predicted effects of the "no action alternative, (Alternative I) in Chapter 4 will establish
the baseline conditions against which the decision maker and the public can compare the
potential effects of Alternative II through VI on the environment.

3.2 Description of Relevant Affected Resources

3.2.1 Montana's Native Deer and Elk Populations (Issue #1)

Montana is populated by two species of deer: white-tailed deer (Odocoelius
virginianus) and mule deer (O. hemionns). The two species have evolved individual
attributes that constrain each to its own ecological niche and contribute to differences
in habitat selection (Mackie, et al. 1998). Mule deer and white-tailed deer are
distributed statewide with an estimated 500,000 or more deer living in Montana.

Figure 2. 2004 Montana Mule Deer Distribution and Population Estimate

Mule Deer Distribution
(Population Estimate = 327,931)

W'j-tdl* l-Hll 'MlJh ll*-vi
lifMnMJcn UiiugniH-l U-£

Lsid Ownership

3 strl&Jtlon Acres

prtvKt

=1 BS1.E7H

Pji-I ■>:-

ii trs.ire

Trba

142,674

"Dial

■ KTjBB

> wiidiye ait, -Pat*;*

34

Figure 3. 2004 Montana White-tailed Deer Distribution and Population Estimate

Hu-tdifthnli 7A LlN 1 I'm- 1.1
lifeiiiBUcii Miii»:>ith-I U-l
hhbni. Ul

White-tailed Dew Distribution
(Population E&timate = 237.725J

4ote: DtTtutcn Tappno 'rcEa^]lEtE■.^i'ti^l'■

Land :• v lem * p

DlBlrlbul : i -ztt^i

=rs:::

12 ■ 1 : ' El

Trial

K.B7C

Total

irsi:s;=

! K^jjMTn^wju ■ir^irai

'WiJdl</i>Ciifc-;Ptin\>

Viable deer populations exist in some places and not in others, according to the distribution
of habitat of varying quality. The dynamics of deer populations constantly adjust as the
environment fluctuates whether it's the wide variation in mule deer fawn survival and
population size experienced in the prairie/breaks or the more limited variation that occurs in
white-tailed deer populations on river-bottom habitats augmented by irrigated agriculture.
For example, mule deer numbers in the prairie/breaks can double in as little as two years
during favorable environmental conditions. In such years, fewer than 20 percent of fawns die
in their first year of life and only a percentage or two of adults die of natural causes. When
conditions are unfavorable, deer numbers can decline up to 50 percent in a single year.
During the severest of conditions, 95 % of all fawns may die before their first birthday and
25-35 % of adults can succumb to natural causes of mortality. In contrast, mortality patterns
for white-tailed deer in river-bottoms associated with irrigated agriculture display less annual
variation. Fawn survival and recruitment averages 75+/- 20 fawns/100 adult females which
is the highest recorded among all deer populations studied in Montana. Because of high fawn
recruitment rates, and low-moderate natural losses of adult females (11-16 percent), whitetail
populations in these environments can sustain comparatively high hunter harvest rates
(Hamlin and Mackie 1989, Mackie et al 1998). The effects of disease-related mortality on
deer population dynamics can only be understood in the ecological context of other important
factors that influence populations.

Movement and dispersal of mule deer and white-tailed deer is tied directly to the preferred
habitats of the distinct species that is in turn tied to the environmental adaptations that the

35

species have acquired through time. Morphological differences such as body size,
musculature and gait, coloration, and antler growth make mule deer more suited to life in dry,
open, rugged terrain and white-tailed deer more suited to dense deciduous woodland. Subtle
differences in digestive systems and physiology of the two species can also be associated
with habitat selection. While mule deer are better adapted to handling larger amounts of
coarse forage typical of dry, open areas, white-tailed deer are restricted to more succulent,
higher quality foods which is evident from the species' close association with agricultural
lands. These and other behavioral and environmental resource issues determine the
movement and dispersal of members of each of the species (Mackie et al. 1998).

Although movement and dispersal is a complex topic that is difficult to generalize, members
of both species would prefer as their fundamental strategy to inhabit one local environment
for yearlong residency that would supply all of their basic requirements. When resource
requirements cannot be met in one local area, specialized uses and use of home ranges begin
to develop. Habitat differences across Montana result in varying home range sizes for mule
deer and white-tailed deer depending on the area. In a study of mule deer and white-tailed
deer inhabiting a 543 km 2 area of eastern Montana prairie, mule deer occupied home ranges
varying from 0.5 km 2 to 19.7 km 2 for winter home range and 0.5 km 2 to 6.2 km 2 for summer
home range. Similarly, white-tailed deer had winter home ranges varying from 1 . 1 km 2 to
13.7 km 2 and summer home ranges varying from 0.5 km 2 to 8.8 km 2 (Wood et al. 1989).
Movement patterns for white-tailed deer, however, were not as discreet as those of mule deer
and varied in response to the distribution of available forage and cover resources over time.
White-tailed deer showed less fidelity to home range with emigration of white-tailed deer,
especially females, from home ranges more common than for mule deer. One radio collared
white-tailed doe in the study of eastern Montana prairie populations left the home range at 3
years of age and was shot 2 years later 93 km away.

Rocky Mountain Elk (Cervus elaphus) are generally associated with coniferous mountain
habitats in western and central Montana. Elk also can be found in coniferous breaks habitat
along major drainages. Although elk utilized open grassland habitats in eastern Montana
prior to settlement of the prairies, current elk populations use extensive areas of conifer
forests for security cover. Consequently, elk are sensitive to cover loss in logged and roaded
forests. Elk will often avoid areas intensively grazed by cattle, especially during the growing
season. An estimated 130,000 to 160,000 elk live in Montana.

36

Figure 4. 2004 Montana Elk Distribution and Population Estimate

Elk Distribution

(Population Estimate = 13B.496)

H>?pmJ_niJ Iff

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lihrn^feriLHiiufnin-IU-t
Hataii. HI

Lsr : OM-Jshh

D j:rlDj:lon -cr-ss

Flv?.:?

ic.^s.^s

PJDlt

: .r$4.4S=

Trlba

.::■ .e«

- 3|J|

M.ECa.MT

Elk feed on a combination of grass and forbs on a yearlong basis with grass generally
dominating the diet. Shrubs can be an important part of the diet during winters of deep snow
cover and depleted grass resources. Elk are elevationally migratory in mountainous areas of
Montana, concentrating on low elevation southerly exposures during the winter. However,
elk generally winter at slightly higher elevations than mule deer and have a greater tolerance
for snow cover. Low elevation elk populations in eastern Montana show some seasonal
shifts in distribution from summer to winter. Higher elevation elk of western Montana tend
to have favored calving areas usually at the upper elevation portions of their winter range. In
general, elk are highly mobile and have large home ranges (Mussehl and Howell, 1971).

Seasonal migrations among Montana's elk herds from summer to winter ranges vary
depending on habitat resources and topography. Cow elk in the Gravelly- Snowcrest area
migrate between 13 and 72 miles with emigration from the herd as much as 121 miles and
immigration as much as 105 miles. Individual bulls in the same herd have shown emigration
maximums of 250 miles to near Ten Sleep, Wyoming. Immigration into the area of
individual bulls has been as far as 125 miles from the National Elk Refuge in Jackson,
Wyoming (Hamlin and Ross, 2002). Cow elk from the Lower Clark Fork herd have been
documented to migrate from 7 to 30 miles during the year while emigration of both bulls and
cows of up to 90 miles has been documented (Henderson and Sterling, et al., 1993). Annual
migration movements of elk in the Blackfoot Clearwater -South Fork Flathead herd has been
shown to be as much as 27 miles for cows and 51 miles for bulls (Hurley, 1994). Elk in the
Gallatin Drainage show maximum migration distances of 35 to 40 miles with at least half the

37

population migrating only about half that far (Hamlin, personal communication). A 3-year-
old bull elk that was shot on the C.M.Russell Wildlife Refuge in the Timber Creek area in
November of 2002 had been tagged on the Theodore Roosevelt National Wildlife Refuge in
Medora, North Dakota as a calf and had probably traveled in excess of 200 miles (Tim
Feldner, personal communication). In October of 2003, a bull elk shot north of Hinsdale,
Montana was identified as an alternative livestock (game farm) animal that had escaped from
an alternative livestock facility in Climax, Saskatchewan, a distance of over 80 miles.

MFWP has been testing the wildlife populations of Montana for the presence of CWD since
1996. An early surveillance program in wild elk was initiated in areas adjacent to
Yellowstone National Park in 1996 to determine if the disease might have moved northward
out of Wyoming. Increased surveillance activities began in 1998 following a directive from
the Governors Office for Montana Fish, Wildlife & Parks (MFWP) and Montana Department
of Livestock (DoL) to work together on surveillance and control of this disease. MFWP
developed and adopted a more detailed surveillance program in October 1999 for wild deer
and elk. The purpose of the survey was to determine the presence or absence of the disease
in wildlife with some as yet to be determined statistical reliability. Statistical reliability is
dependent upon sample size, population size, and success of collection, which are
constrained by access to samples (check stations) and various harvest regulations
(opportunity to hunt deer or elk) within each area. This 1999 plan included broad geographic
surveys, special collections, and targeted surveys. Initially, the broad geographic surveys
emphasized the central and southern portions of Montana where deer and elk are most
common and where CWD would naturally spread from Wyoming, South Dakota or Colorado
where it was currently found. After the discovery of CWD in Saskatchewan Canada,
emphasis was also directed to region 6 along Montana's northern border with Canada. Since
2000, surveys have concentrated on high-risk areas, where MFWP considers possibility of
detecting the first case of CWD in Montana the greatest. The high-risk areas include
Saskatchewan border with Montana (region 6) and along the border with Wyoming and
South Dakota (regions 3, 5, and 7). An additional high-risk area was added in 2000 and
included the area around an alternative livestock ranch where captive cervids had been
diagnosed with CWD in late 1999 (region 2). Special sample collections were conducted by
FWP outside of hunting seasons as opportunities presented themselves. Targeted surveys
emphasized animals with clinical symptoms collected by the field biologists and wardens
throughout the state (Anderson, N, and K. Aune. 2004).

The results of the surveillance surveys conducted since 1998 are presented in Table 4. With
the addition of over 300 samples collected during a late hunt outside of Yellowstone National
Park in early 2005, there have been over 7000 samples tested since 1998 with no deer or elk
testing positive for CWD in Montana.

38

Table 4. CWD Survey Result Totals for Montana from 1998 through 2004

Year

Hunter

Road
kill

Targeted

Special

Total (PrP
not detected)

1998

443

1

2

446

1999

575

3

4

582

2000

240

2

20

74

336

2001

191

1

18

10

220

2002

976

4

18

998

2003

2002

3

31

96

2132

2004

2050

28

13

2091

Total

6477

42

106

180

6805

3.2.2 Wildlife Management Tools (Issue #2)

The historical concept of deer and elk management from the 1930's until the mid-1970's
stressed that the number of mule deer, white-tailed deer, or elk able to be sustained in a
given area was a function of the availability of appropriate habitat and forage. Populations
reaching high densities overgraze available forage, particularly on winter ranges. The
decline in habitat quality results in high mortality rates and low fawn recruitment rates
causing precipitous drops in populations that take years to recover. Over-utilized habitat
may take 10-20 years to recover to a condition that will support a population increase.
Management of deer and elk populations under the historical management objectives were
accomplished in two manners: by providing more available habitat and thereby more
forage, especially on winter ranges, or by maintaining populations that could be supported
by the existing habitat and forage. A successful management program attempted to
maintain quality habitat by properly harvesting excess animals when necessary.
Management hunts (general and late season to manage population size and distribution) are
the primary tool for control of the wildlife populations within the limits of existing habitat
and forage. Those hunts must achieve consistent population reductions in order to be
successful. Obtaining an adequate harvest is sometimes restricted by rugged terrain or by
private ownership of land where access is restricted.

Wildlife biologists now believe that the population dynamics and ecology of deer and elk
are much more complicated than the cause and effect relationships between available
forage and habitat and population numbers. Rather than the traditional view of a balance
between a few components such as deer density and forage quantity, wildlife biologists
now believe that deer populations function in complex ecosystems and vary in accordance
with a balance of the total environment (Mackie et al. 1998). The most influential factors
in deer population dynamics seem to be weather, habitat condition, predation and other
natural mortality, and hunter harvest. Although harvest of deer and elk by hunting
mortality is still the essential and most easily controllable management tool, not only
available habitat, but an array of environmental variations affect fawn recruitment rates and
natural mortality rates and must be considered when determining the "window of
opportunity" for hunter harvest.

39

Until recently, Montana's mule deer population was managed as one continuous population
across the state. Under Montana FWP's Adaptive Management Plan initiated in 2001, five
population management units have been identified based upon mule deer population
dynamics and habitat characteristics. Those management units include the Northwest
Montane, the Mountain Foothills, the Prairie/Mountain Foothills, the Southern Mountains,
and the Prairie Breaks. "Population indicators" for each of the population management
units have been established based upon historical population data to define objectives for
each unit and to aid the department in developing regulations (standard, liberal, and
restrictive) for hunting season recommendations to the FWP Commission (MFWP-
Adaptive Harvest Management, 2001). In studying and managing the deer populations,
mortality factors, habitat carrying capacity, reproduction and recruitment, and many other
factors are taken into consideration to provide instructive insight into proper actions
required to manage the populations at preferred levels. The goal of the adaptive
management plan is to "manage for the long-term welfare of Montana's deer resource and
provide recreational opportunities that reflect the nature of the deer populations." The
major components of the Adaptive Management Plan are population objectives, monitoring
program, hunting regulation alternatives, and modeling.

A primary management tool used by wildlife professionals is the big game hunter. By
adjusting harvest quotas in population management units as well as the population segment
targeted (antlered vs. antlerless), game management objectives for male:female ratios and
for manipulation of total populations numbers have been achieved in most areas. New
evaluation techniques, introduced with the 2004 Draft Elk Management Plan issued by
FWP in September of 2004, will provide increasingly sophisticated information upon
which quotas can be established for management of the elk herds. The adaptive harvest
management plan employed by FWP for mule deer and white-tailed deer will provide the
same information concerning management.

The annual mule deer harvest in Montana has ranged from about 42,000 to 92,000 animals.
The annual white-tailed deer harvest in Montana has been increasing steadily with 65,000
white-tailed deer harvested in 1996. In 2001, almost 170,000 hunters took to the field
during deer season resulting in a harvest of almost 1 12,000 mule deer and white-tailed deer
combined. Similarly, over 100,000 elk hunters took to the field in 2002. The annual elk
harvest has been increasing in recent years from an average of 15,000 to a current average
of about 30,000 animals.

3.2.3 Wildlife and Montana's Economy (Issue #3)

Hunting in Montana is big business. Almost two-thirds of Montana's hunters are Montana
residents with a 24% rate of participation in hunting among Montana residents. Statistics
suggest that approximately 44% of Montana's adult male population and 13% of
Montana's female population purchase a hunting license annually. In 2002, elk license
sales to Montana residents generated almost $1.9 million in income to MFWP and non-
resident elk license sales generated $1 1.7 million in income to MFWP. This total of $13.6
million was about 53% of all license fees received by MFWP and does not include elk
permit drawing fees, archery license fees, or conservation license fees not included in
license packages. In 2002, total deer license sales to residents and non-residents generated

40

$5.2 million in license fees. In addition, deer and elk hunters accounted for a large share of
the $5.6 million in Federal Pittman-Robertson funds distributed to MFWP as a result of
federal excise taxes collected on the manufacture of rifles, handguns, ammunition, and
archery equipment. Thus, elk and deer hunting are of major importance in direct funding to
MFWP for conservation and management programs for elk, deer and other wildlife species
native to Montana.

In addition to providing funding to MFWP through the sale of hunting licenses, the hunting
and wildlife viewing industry in Montana are substantial contributors to the state's overall
economic output. In 2001, hunters spent an estimated $237.6 million in Montana (USDI,
Fish and Wildlife Services and U.S. Department of Commerce, U.S. Census Bureau 2003).
Big game hunting accounted for about 80% of this total. Wildlife viewing provided an
additional estimated expenditure of $350 million. Thus hunting and wildlife watching
accounted for an estimated $589 million in expenditures in Montana. This expenditure
was equivalent to about 1.6% of the total economic output for Montana in 1999 (Minnesota
IMPLAN Group, 2002). The amount spent on hunting and wildlife viewing represents
23% of the economic output provided by farming, ranching, and agricultural services
combined in Montana in the same time period. Similar comparisons are 62% of the
combined economic output of all mining, 38% of the output of the petroleum industry, and
32% of the combined output of forestry products, wood products, and pulp and paper. All
of these dollars provide a "multiplier effect" as the money spent for lodging, fuel, sporting
goods, equipment, etc. are then used to provide jobs and income to local communities
where the dollars generated are again turned over to purchase more local goods and
services.

3.2.4 Human Health (Issue #4)

There are a number of transmissible spongiform encephalopathies (TSEs) that affect
humans. Most of the TSEs affecting humans occur as a sporadic disease with no
identifiable source of infection or as a familial disease linked with mutations on the prion
protein gene (Belay, ED, 1999). A notable exception among the human TSEs is the variant
form of Creutzf el dt- Jakob disease (vCJD), which is associated with the foodborne
transmission of bovine spongiform encephalopathy (BSE or "mad cow") to humans (Will
et al. 1996). Unlike sporadic CJD, vCJD, affects a younger population and causes some
distinguishing diagnostic characteristics in its victims allowing differentiation from
sporadic CJD. As of December 1, 2003, a total of 153 cases of vCJD had been reported in
the world: 143 from the United Kingdom, six from France, and one each from Canada,
Ireland, Italy, and the United States (note: the Canadian, Irish, and U.S. cases were reported
in persons who resided in the United Kingdom during a key exposure period of the U.K.
population to the BSE agent) (Center for Disease Control, 2004).

The prion thought to cause CWD has not been shown to affect humans. There is a
perception of risk from CWD, however, due to the association that has been established
between mad cow disease, a domestic animal TSE, and vCJD, a human TSE. That
perception has caused public concern and heightened public awareness of TSE diseases.
There have been numerous reports by the media of big game hunters who have developed
CJD. These reports, for the most part, have not indicated whether the disease diagnosed in

41

the humans has been sporadic CJD or variant CJD. The reports have resulted in
investigations by the Center for Disease Control (CDC) evaluating the risk of CWD to
hunters or to those consuming venison. A causal relationship, such as a food-born link
between CWD and the human illness, could not be identified in any of the cases
investigated. Despite the fact that CWD has been present in free-ranging cervids in
Colorado and Wyoming for decades, the incidence of CJD and the age distribution of CJD
case-patients in these two states are similar to those seen in other parts of the United States
(Belay, et. al., 2004). As mentioned above, there has only been one case of vCJD reported
in the United States. That case involved an individual that had been exposed to the BSE
agent in the United Kingdom prior to moving to the United States. Studies done by CDC
have not identified a link between CWD and any form of prion disease in humans.

As a means of providing additional protection against any potential risk of human exposure
to CWD, the Montana Department of Fish, Wildlife & Parks has suggested that hunters
follow some simple precautions:

• Animals that appear sick should not be harvested or consumed.

• Wear rubber latex gloves when field dressing carcasses.

• Minimize handling and don't eat the brain or spinal cord.

• Bone out the meat and discard the brain, spinal cord, eyes, spleen and lymph nodes.

• Be sure to wash your hands and all utensils after processing your animal.

These precautions provide a degree of protection to individuals not only against any possible
exposure to the CWD prion agent, but also against a number of other pathogens that could
potentially be carried by wildlife.

3.2.5 Alternative Livestock (Issue #5)

Alternative livestock are defined as any privately owned caribou, white-tailed deer, mule
deer, elk, moose, antelope, mountain sheep, or mountain goat indigenous to the state of
Montana, a privately owned reindeer, or any other cloven-hoofed ungulate as classified by
the Department of Fish, Wildlife & Parks (MFWP). An alternative livestock ranch is
defined as an enclosed land area upon which alternative livestock may be kept for the
purposes of obtaining, rearing in captivity, keeping, or selling alternative livestock.
Finally, a person may not operate an alternative livestock ranch in Montana without having
first obtained an alternative livestock ranch license from FWP prior to November 7, 2000.

Alternative livestock production in Montana has been regulated by MFWP since the early
1900's. The legislature passed the original statute directing the administration of
alternative livestock production in 1917. Until the 1980's the number of alternative
livestock operations was relatively small, and without significant controversy. Non-
significant changes to regulations were made as needed. In the 1970's and 1980's
regulations were passed that required alternative livestock operations to be licensed by
MFWP in order to purchase, sell, transport, or otherwise transfer game animals as private
property (Mundinger and Beck, 2000). Currently, the alternative livestock industry is co-
regulated by MFWP and the Montana Department of Livestock (DoL). MFWP has
primary jurisdiction with regard to licensing, reports, recordkeeping, exterior fencing,
classification of certain species, inspection of exterior fences and records, and unlawful

42

capture. DoL has jurisdiction with regard to marking, inspection of interior facilities and
animals, transportation, importation, quarantine, hold orders, interior facilities, and health
of the alternative livestock.

The number of alternative livestock licensees in Montana increased dramatically in the
1990's. At that time, the industry was considered by some as an opportunity to supplement
traditional livestock income sources. Some excellent resources, including a Michigan
"white paper" (Captive Cervid White Paper, 1999) have been prepared describing the
markets for captive raised deer and elk in North America. Those markets, especially the
elk breeding stock market, experienced substantial growth in the 1990's with prices for
breeding stock peaking in 1996. In comparing select sale prices of elk breeding stock
obtained from 1996-7 auctions to those prices obtained in 1998 and early 1999, Watson
(1998) concluded that the overall elk breeding stock prices "are down 35 to 60% from high
posted in 96 and 97".

As of January, 2005, there were 61 licensed alternative livestock facilities in Montana that
reported a total of 2600 alternative livestock animals, approximately 95% of which were
elk, behind their exterior fences. These facilities generate income from the sale of breeding
stock, meat or animal products, and velvet antler. Prior to November, 2000, an additional
source of income to a limited number of licensees had involved the charging of a fee to an
individual for the opportunity to shoot alternative livestock. That method of revenue
generation was eliminated in November, 2000 by the passage of a citizen's initiative,
Initiative 143 (1-143). 1-143 prohibited the shooting of alternative livestock for a fee, the
issuance of any new alternative livestock licenses by MFWP, and the transfer of an
alternative livestock license to a third party. Both the state of Montana and MFWP have
been named in numerous lawsuits that have sought either a reversal of the elements of I-
143 due to issues of "unconstitutionality" or a payment to the plaintiffs for a "taking" of
private property or private property value without any just compensation. In all cases
decided to date, the constitutionality of 1-143 has been upheld and the courts have found
that the implementation of 1-143 did not result in an uncompensated taking of property.

As of June of 2005, CWD has been diagnosed in captive cervids in 9 states and 2 Canadian
provinces. Animals from at least 36 captive alternative livestock herds in the U.S. and 46
herds in Canada have tested positive for CWD. In most cases, the infected herds have been
depopulated. CWD was diagnosed at a Montana alternative livestock facility in November
of 1999. That herd was depopulated and all 87 animals (elk) tested for CWD resulting in
the detection of 9 animals positive for CWD. A trace quarantine herd was identified in
Montana that had received elk from the original CWD infected herd. All 29 elk from that
trace quarantine herd were also killed and tested for CWD. None of those trace herd
animals were positive for CWD.

Currently, the Montana Department of Livestock requires by their administrative rules that
any alternative livestock animal over 16 months of age that dies on an alternative livestock
ranch in Montana be tested for CWD. Since initiation of that program in 1999, almost
3500 samples have been submitted from alternative livestock ranches for CWD testing.

43

Only 9 samples, all from the 1999 index herd mentioned above, have tested positive for
CWD.

Once CWD is found in a captive herd, that herd is quarantined and an epidemiological
investigation initiated to identify any trace back and trace forward herds. Any herds
identified as CWD positive or CWD exposed are subsequently quarantined and a herd
health program established. In the case of a CWD infected herd, depopulation has
generally been conducted to enable CWD testing of the entire herd. Indemnification
programs through the USD A/ APHIS will provide payment to the operator at a rate of 95%
of the appraised value of the animals up to a maximum of $3000 per animal. Indemnity
payments currently require the entire depopulation of the captive cervid herd that is
determined to be CWD positive with no restocking on depopulated premises without
APHIS approval.

USDAAPHIS published proposed rules for "CWD Herd Certification and Interstate
Movement of Captive Deer and Elk" in December of 2003. That program is intended as a
national program to help prevent the spread of CWD within the captive cervid industry and
the free ranging populations of cervids in the U.S. The program requires CWD testing for
all animals that die on the premises over 16 months of age, individual identification of
every animal in the herd, and maintenance of complete records concerning date of
acquisition, source, date of disposal and destination of any animal removed from the herd.
Following 5 years of compliance with the herd certification program, the herd is given a
"certified" status which is maintained as long as the herd stays enrolled in the program and
continues to fulfill the requirements. Interim status levels of 1 through 5 are given based
on the number of years that the herd has been successfully enrolled in the certification
program. Certified status 5 eliminates the requirement for CWD testing of animals that are
slaughtered or that are killed on "shooter" operations. The program is expected to become
codified upon finalization of the proposed rules in 2005.

Many individual states, including Montana, have established programs similar to the
proposed federal program and alternative livestock licensees will be given consideration
when entering the federal program for years enrolled in qualified state programs. Montana
has required the elements of the federal program since 1999 resulting in the testing of
almost 3500 alternative livestock over 16 months of age that have died over the past 5
years. In establishing their current programs, many states have prohibited the importation
of any cervids unless they have originated from out of state facilities that have been
successfully enrolled in a CWD surveillance program for anywhere from 3 to 5 years.
Montana is one of those states that have not allowed the importation of cervids unless
originating from facilities where surveillance programs have been in existence for 5 years.
Because of that requirement, Montana has not allowed the importation of any cervids since
1999.

3.2.6 Disposal/Environmental Contamination (Issue #6)
Disposal

The disposal of carcasses and/or offal of domestic and wild animals is an issue regulated by
multiple departments in the state of Montana. In most cases, deer or elk harvested in the

44

field have been field dressed at the site of harvest and the internal organs left for
scavengers. The inedible remains of hunter-harvested animals following processing have
been disposed of at the discretion of the hunter or processor, but hopefully at municipal
solid waste landfills. Due to the "waste of game" statutes in place in Montana, these
remains have been composed primarily of skeletal remains and remnants of meat not easily
removed from the bones.

In the case of meat processors, the material remaining after processing, which may amount
to over 35% of the original body weight of the dead animal, may be taken to rendering
facilities. Rendering facilities retrieve the fat and protein from these remains through
heating at 125-135 degrees centigrade followed by extraction procedures. The final
products containing the fat and protein are utilized in many domestic products, but
primarily in pet feed, poultry feed, and swine feed. In 1997, the FDA prohibited the use of
rendered protein and bone meal obtained from ruminants for use in feed for other
ruminants. In addition, on November 12 2002 the FDA announced that "the Agency will
not permit material from Chronic Wasting Disease (CWD)-positive animals, or animals at
high risk for CWD, to be used as an ingredient in feed for any animal species" (FDA,
Center for Veterinary Medicine, 2002).

Road killed wild animals have been disposed of under agreement with the Montana
Department of Transportation by highway maintenance crews. These carcasses are
disposed of, once again, in municipal solid waste landfills. Wild game that dies naturally
in the field (either private or public lands) is almost always left to decompose naturally or
is consumed by scavengers.

In the case of animals suspected of dying from contagious diseases, the primary goal of
carcass disposal is to prevent spread of the disease agent to other animals. In the event of
an outbreak of a foreign animal disease, special measures are needed to ensure the disease
agent is eradicated to contain the outbreak and prevent its revivification at a future time. In
some cases, the agent will not survive long after the death of the infected animal and proper
burial is sufficient for the animal carcass. Other diseases can require incineration.
Determining the required option to contain the disease and protect future animals from it is
addressed on a case-by-case basis by state agencies. It is the owner's responsibility to
properly dispose of animals he or she knows to be sick (see Department of Livestock
Statutes later in this section). Diseases that agencies are typically concerned with are Hoof
and Mouth disease, Anthrax, and Transmissible Spongiform Encephalopathy's. Options
for disposal in these cases include burial at an engineered and regulated landfill, rendering
with controlled disposal, incineration, and digestion by high pressure- high temperature-
alkaline hydrolysis.

Modern landfill sites include engineered liners, caps, and leachate and gas collection
systems and provide an excellent capacity for carcass disposal. They are relatively low
cost as compared to other methods of disposal. The Wisconsin Department of Natural
Resources prepared a risk assessment on the disposal of potential CWD infected deer from
Wisconsin in municipal solid waste landfills (Wisconsin DNRC, 2002). In that analysis,
they determined that the primary pathway of potential risk identified for the CWD prion

45

following landfill disposal of infected deer can be described as
carcass=>landfill=>leachate=>wastewater treatment plant=>sludge=>farm field^>ingestion
by humans or deer/elk. While they concluded that a quantitative or semi-quantitative
assessment of the risk was not possible due to unknowns such as the quantity of infectious
agent in a deer carcass and the dose required for infection, they did conclude that it was
"reasonable that while absolute numbers relating to human health risk cannot be generated,
the available knowledge about CWD and other TSEs suggests that landfilling of CWD-
infected deer does not pose a significant risk to human health." The Wildlife Diagnostic
Laboratory disposes of cervid tissue remnants from the surveillance program by landfill.
These carcasses do not present a risk at this time. If CWD becomes "endemic" in areas of
Montana, disposal methods for those materials will be re-evaluated.

Rendering as a means of disposal of animal carcasses involves cooking of animal tissues at
specific temperatures for set time periods, to produce water, tallow (fats) and meat and
bone meal (the protein portion). Rendering involves some level of inactivation of the prion
agent and may reasonably be expected to reduce infectivity by 10-100 fold. Studies
using BSE and scrapie agents, however, indicate that TSE agents can survive rendering to
some degree. Controlled disposal would be required since the tallow and meat-and-bone-
meal could contain infectious agent and could not be marketed for fertilizer or animal feed.
There are potential concerns regarding water contamination and quality. If water from the
process contained solids the prion agent could "stick" to this. Filtering solids from the
wastewater before discharge could reduce potential infectivity in wastewater. The use of
the rendering option for disposal may be limited by refusal of rendering plants to accept
cervids (as happened in Wisconsin following the discovery of CWD in the area) (Bartelt,
G., Pardee, J., & Thiede, K. 2003)

Incineration is another method for disposal of animal carcasses. Montana maintains an air
curtain incinerator for the incineration of large numbers of contaminated materials to
prevent contamination of the environment. Incineration is a highly effective method for
complete inactivation of the prion protein responsible for TSE diseases if temperatures are
sufficiently high. Air curtain incinerators will reach temperatures of 1800 °C to 2800 °C
when operated properly and will provide efficient incineration and inactivation of the prion.
Air curtain incinerators utilize an open topped pit or combustion box, are commonly fueled
with wood, and have a fan along the length of the pit or box to both provide the oxygen
necessary for high temperature combustion and an air curtain preventing the escape of
smoke or unburned particulate from the pit or box. Air curtain incinerators have the
capacity to incinerate as many as 100 elk carcasses in a day.

Finally, alkaline hydrolysis may be used for disposal of CWD infected carcasses or
carcasses at high risk of contamination with the CWD agent. The tissue digestion
equipment is expensive and has a low volume capacity. The process does, however,
provide for inactivation of TSE agents and results in a sterile aqueous solution of small
peptides, amino acids, sugars, and soaps. By-products consist of the mineral constituents
(ash) and softened bones and teeth remnants that can be recovered as sterile bone meal.
The process uses alkaline hydrolysis at an elevated temperature to convert the proteins,

46

nucleic acids, and lipids of all cells and tissues, as well as infectious microorganisms and
TSE agents.

Carcass disposal became an issue in Montana after finding CWD on an alternative
livestock ranch in southwestern Montana. Eighty-seven animals either died or were
sacrificed and samples taken for diagnosis and research. Initially, the carcasses were slated
for disposal at a municipal landfill. Those plans, however, were abandoned when county
authorities at the landfill location balked at disposing of the potentially contaminated
carcasses in that county. Eventually, carcasses were disposed of by incineration using a
trench incineration technique that incorporated an air curtain to completely incinerate the
elk carcasses.

Statutes and Rules Regarding Animal Carcass Disposal in Montana:

Department of Environmental Quality Statutes:

75-10-212. Disposal in unauthorized area prohibited — exception. (1) No person may
dispose of solid waste except as permitted under this part. (2) It shall be unlawful to dump
or leave any garbage, dead animal, or other debris or refuse: (a) in or upon any highway,
road, street, or alley of this state; (b) in or upon any public property, highway, street, or
alley under the control of the state of Montana or any political subdivision thereof or any
officer or agent or department thereof; (c) within 200 yards of such public highway, road,
street, or alley or public property; (d) on privately owned property where hunting, fishing,
or other recreation is permitted, provided this subsection shall not apply to the owner, his
agents, or those disposing of debris or refuse with the owner's consent. (3) Any person in
violation of this section is absolutely liable, as provided in 45-2-104 , and is subject to the
civil penalties provided in 75-10-233 .

75-10-213. Unlawful disposition of dead animals ~ exception. It is unlawful to: (1)
place all or any part of a dead animal in any lake, river, creek, pond, reservoir, road, street,
alley, lot, or field; (2) place all or any part of a dead animal within 1 mile of the residence
of any person unless the dead animal or part of a dead animal is burned or buried at least 2
feet underground; or (3) being the owner, permit all or any part of a dead animal to remain
in the places specified in subsections (1) and (2) of this section except as provided in
subsection (2) of this section.

75-10-214. Exclusions ~ exceptions to exclusions. (1) (a) This part may not be construed
to prohibit a person from disposing of his own solid waste that is generated in reasonable
association with his household or agricultural operations upon land owned or leased by that
person or covered by easement or permit as long as the disposal does not create a nuisance
or public health hazard or violate the laws governing the disposal of hazardous or
deleterious substances, (b) This part does not apply to the operation of an electric
generating facility, to the drilling, production, or refining of natural gas or petroleum, or to
the operation of a mine, mill, smelter, or electrolytic reduction facility. (2) The exclusions
contained in subsection (1) of this section do not apply to a division of land of 5 acres or
less made after July 1, 1977, that falls within the definition of subdivision in Title 76,
chapter 4, part 1, or the Montana Subdivision and Platting Act in Title 76, chapter 3.

47

Montana Department of Livestock Statutes:

81-2-108. Diseased animals not to run at large —burial of carcasses. It shall be
unlawful for any owner, agent, or person in charge of any domestic animal or animals that
are known to be suffering from or exposed to a dangerous, infectious, contagious, or
communicable disease to permit such animal or animals to run at large on the public range
or public highway. It shall be the duty of the owner or agent or person in charge of
animals, which died, or they have reason to suspect did die from an infectious, contagious,
communicable, or dangerous disease to properly bury or burn the same.

Montana Department of Livestock Administrative Rules:

32.3.125 DISPOSAL OF CARCASSES (1) Carcasses of animals that have died from
other causes than anthrax must be disposed of in a satisfactory manner so as not to become
a public nuisance or a menace to livestock or poultry. Carcasses of dead animals may not
be disposed of along public highways, streams, lakes, or rivers, or allowed to remain on the
ground surface so as to become a public nuisance or a menace to livestock or poultry

32.3.1002 HANDLING OF CARCASSES AND CARCASS PARTS OF ANTHRAX
INFECTED ANIMALS (1) The carcasses of animals which have died of anthrax may not
be skinned or opened, except when considered necessary by a deputy state veterinarian in
order to make a definite diagnosis.

(2) Hides from carcasses of animals that have died of anthrax shall not be
removed. Hides which have been removed prior to diagnosis of anthrax shall be burned or
buried.

(3) Carcasses of animals that have died of anthrax must be completely burned,
covered with quick lime and buried 6 feet deep from the tip of the carcass, or sterilized in a
licensed rendering plant under the immediate supervision of a deputy state veterinarian.

(4) If it is necessary to move the carcass of an animal that has died of anthrax, the
natural openings must be plugged with cotton or other suitable material.

(a) The carcass must be rolled onto a stone boat or skid and hauled to the nearest
spot suitable for burning or burial.

(b) The stone boat or skid must be burned or thoroughly disinfected.

(c) Carcasses may be moved in an approved licensed rendering plant truck by
written permission from and under the supervision of a deputy state veterinarian.

48

32.3.1002 HANDLING OF DEAD ANIMALS OR FOWL

(3) Where bodies, or parts of bodies, of dead animals or fowl are to be converted into tallow
and other inedible material, the processing or rendering and cooking must be done in a manner that
insures that all material is sterile.

(4) Where bodies, or parts of bodies, of dead animals, or fowl (including viscera contents)
are to be disposed of by burning, the burning must be complete. The place where burning is done
must be located, constructed and arranged to not interfere with the comfortable enjoyment of life and
property of residents of this state.

(5) Where bodies, or parts of bodies, of dead animals or fowl (including viscera contents) are
to be disposed of by burying, they must be buried so that no part shall be nearer than 4 feet from the
natural surface of the ground. Every part must be covered with quicklime and then 4 feet of earth.
The burial pit may not be located near any river, stream, lake, pond, well, or any gulch or draw
which is the source of any stream. The burial pit may not drain on any ground, which may be
flooded by the overflow water of any river, stream, lake or pond.

(6) If disposition of the viscera contents or parts of carcasses is to be made in any manner
other than as provided in these rules, the disposition must be approved by the department after
written application by the licensed renderer.

Environmental Contamination

The role that environmental contamination plays in the transmission and epidemiology of CWD
remains unclear. There is concern, however, that the potential exists for indirect natural
transmission of CWD through contamination of the environment by excretions, secretions, or the
decomposition of infected animal carcasses. (USD A/ APHIS, 2002) Studies recently completed in
Colorado (Miller, et al. 2004) have provided preliminary information concerning environmental
contamination. In one study, CWD negative animals placed in a pen that had contained CWD
infected animals 2.2 years earlier eventually developed CWD as a result of the environmental
exposure. In a second study, deer developed CWD following exposure to carcasses of CWD
infected deer that had been placed in pens 1.8 years earlier and allowed to decompose. These
findings indicate that "environmental sources of CWD infection represent potential obstacles to
control in natural and captive settings." Fearing environmental contamination, at least 15 states have
imposed carcass import restrictions concerning importation of heads and spinal cords of deer and elk
harvested from other states. The implications of the Colorado environmental studies on carcass
import should, however, be taken in context. First, the infective material used as the "contaminant"
in the Colorado studies originated from animals that were either in the end stages of CWD or had
died of CWD. In the wild, the majority of CWD infected animals harvested, if any, would not be
showing clinical symptoms and would conceivably not have the concentration of abnormal prion in
the nervous tissue and lymph tissue that the study sources did. Viscera and other wastes left in the
field by hunters harvesting normal appearing animals would provide much less of an "infective
dose" than that provided by the experimental animals as would the brains and spinal cords brought
home or to the meat processor. Second, the experimental animals in the Colorado study were
confined in relatively small pens where repeated exposure to the contaminated material was more
likely to occur.

49

Prions, the theoretical causative agent of CWD and other TSE's, are highly resistant to standard
decontamination procedures and agents typically used to inactivate other "pathogens." Those
decontamination procedures include ultraviolet light, temperature extremes, and oxidizing agents.
At the present time there does not appear to be a practical way of disinfecting large areas of
contaminated ground in order to deactivate the CWD agent. To date de-stocking and disinfecting
CWD-infected premises, followed by restocking after an interval of time, has not been successful in
eliminating the disease on the premises. The reasons for such failures are not known. Further
research is required to determine how effective disinfection of large areas (e.g. deer or elk farms) can
be carried out.

3.3 Other Regulatory Agencies

Federal agencies and other Montana state agencies either have plans in place or are in the
process of preparing plans for prevention and/or management of CWD in captive cervid and/or
free-ranging cervid populations. Those plans, separated by responsible agency, are
summarized below. In addition, overviews of CWD action plans developed by other states
have been summarized to allow for a comparison with alternatives presented in this plan.

USDA/APHIS

In September of 2000, the Veterinary Services division of USDA/APHIS proposed a program
designed "to eradicate CWD from captive elk herds in the United States". That program
entitled "Chronic Wasting Disease Herd Certification Program and Interstate Movement of
Captive Deer and Elk" was published and made available for comment in the Federal Register
in December of 2003. Elements of the program include requirements for animal identification,
testing, herd management, and movement of animals into and from herds. After 5 years of
participation in the program with no evidence of CWD, a herd would be granted a "certified"
status and movement of captive cervids from that herd allowed for interstate commerce.
Comments on the program design have been collected by USDA/APHIS and implementation
of the plan is expected in late 2005.

USFWS

In anticipation of finding CWD on United States Fish and Wildlife Service (USFWS) lands,
planning guidelines were prepared by USFWS in February of 2004. The guidelines were
intended to assist Regions in working with their field stations (primarily refuges and
hatcheries) to develop site-specific plans for CWD surveillance and for management of CWD
should it occur on USFWS lands. The guidelines placed a high priority on coordination of
actions and shared use of resources with state wildlife agencies, other state and federal
agencies and other partners. Plans for specific each of the USFWS stations in Montana were
prepared by October of 2004. Information was provided to field station personnel by MFWP
to assist in their plan preparation.

DoL

The Montana DoL instituted a program for surveillance of CWD in captive cervids in April of
1999. Elements of that program include annual inventory inspections, reporting of deaths of
all animals that have been individually identified (individual identification required by January
1 of the year following their birth) and CWD testing of all animals that die and are 16 months
of age or older. Herds of origin wishing to import animals into Montana were initially required

50

to have a 12-month surveillance period in compliance with the Montana requirements. That
12-month requirement was modified to 24 months in November of 1999 and modified once
again in February of 2000 to 60 months.

Idaho CWD Action Plan

Idaho has prepared a CWD plan that includes elements of risk reduction for the appearance of
CWD, surveillance for the presence of CWD, and containment of CWD should it appear in the
state. The essential elements of the containment or management plan are as follows.

1 . If CWD is diagnosed in the wild or a captive facility, the Idaho Department of Fish and
Game (IDFG) will immediately collect samples from 50 deer within a 5-mile radius of
the affected site. If CWD is not detected in these samples, general surveillance at
hunter check stations will be conducted in the affected Game Management Units using
statistically generated sampling sizes to detect the disease at a 95% confidence interval.

2. If CWD is detected in the 50 deer sampled, the deer and/or elk population will be
reduced 25-50% within 5 miles of the affected site using IDFG personnel and hunters.
In addition, eradication effects may be initiated for deer and elk within a 1-mile radius
of known infected animals.

3. If CWD is detected in subsequent general surveillance, the deer and/or elk population
will be reduced 25-50% within 5 miles of the affected site using IDFG personnel and
hunters. In addition, eradication effects may be initiated for deer and elk within a 1-
mile radius of known infected animals.

South Dakota CWD Action Plan

The goals included in South Dakota's CWD Action Plan are to monitor the occurrence and
spread of CWD in free-ranging cervids, to prevent the further spread of any CWD in free-
ranging cervids and eliminate the infection where it exists, and to educate the public
concerning CWD. Their management and elimination program includes the following actions:
The response to a finding of CWD in free-ranging cervids will be based on a 10% sample of
the baseline populations.

1. <1% infection rate = monitor through hunter harvest (voluntary submission) with
increased tags to reduce herd.

2. 1-3% infection rate = (#1 guidelines) plus GFP organized sampling to confirm infection
rate and to further reduce herd.

3. 3% infection rate and above = mandatory hunter harvested checks, attempt to
depopulate designated zone of infection.

a. Unlimited, free tags in the zone during season established.

b. GFP organized cervid reduction by any necessary means.

Utah CWD Action Plan

Utah's goals for management of CWD in free-ranging cervids are to: 1) prevent introduction of
disease into free-ranging populations and captive herds; 2) eradicate the disease when it is
detected in new areas or herds; and 3) reduce prevalence of disease in endemic areas to
minimize effects of the disease on wild populations. Their management plan has four specific
goals that are presented below:

51

Goal 1: Prevention: To maintain populations or areas free from CWD.

• The UDWR will continue to cull and test all wild deer and elk from inside
domestic elk farms. Increased efforts will be made to eliminate wild deer and elk
located inside domestic elk facilities. This strategy will require substantial effort
by UDWR employees not limited to fixed-wing and helicopter flights as well as
attempts for removal from snowmobile.

• The UDWR will continue targeted surveillance efforts throughout the state by
removing and testing samples from all deer, elk, and moose exhibiting clinical
symptoms of CWD.

• The UDWR will work closely with the Utah Department of Agriculture and Food
(UDAF) to prevent introduction of disease into free-ranging populations as well
as prohibiting the disease from entering captive herds. This will be accomplished
by limiting contact between free-ranging and captive animals.

Goal 2: Elimination: To remove CWD and prevent its reintroduction from a specific area.

• When CWD is detected in a new area, the UDWR will initiate an outbreak
surveillance program and cull animals from the area to determine the extent of the
infection and attempt to eradicate CWD from the area. This strategy, also known
as "hot-spot culling", is an attempt to identify foci of CWD infections, determine
infection rates, and cull local populations to reduce prevalence and spread of the
disease. Generally, this effort will require taking and testing of deer by UDWR
personnel. In addition to culling efforts, the UDWR will use targeted surveillance
to promptly remove and test samples from all deer, elk and moose exhibiting
clinical symptoms of CWD, regardless of location throughout the state.

Goal 3: Maintenance: To maintain CWD below a specified level of prevalence.

• The UDWR will continue to maintain an accurate database of CWD information
utilizing GIS and other systems, which includes sampling data from previous
years efforts. Management this year will include efforts to collect more accurate
locations on all animals that are tested.

• The UDWR will continue to test for CWD with 95% confidence limits at a >1%
prevalence rate.

• The UDWR will reduce or maintain herd populations in CWD positive areas
below herd unit objectives. Hunting will be used as the primary management tool
to reduce deer and elk populations in units where CWD has been detected. All
herd reduction efforts will be coordinated with adjacent states where applicable.

•

The UDWR will look at policies to limit feeding of wildlife in areas where
positive cases have been identified and look at ways to reduce feeding programs
in the state to reduce prevalence and prevent transmission of CWD.

52

Goal 4: Containment: To keep CWD from spreading outside of an area where it is confirmed.
• The UDWR has been working on and will complete a memorandum of
understanding between UDWR, UDAF, and the Utah Division of Solid and
Hazardous Wastes (UDSHW) to ensure that carcasses are disposed of properly.
The UDWR will put together information for the public on the proper care and
disposal of carcasses. UDWR currently has laws in place that restrict the
movement of carcasses that are brought into the state from known positive areas.
We are looking at restricting the movement of carcasses within the state areas
with known positive cases.

•

•

The UDWR will continue targeted surveillance efforts by the prompt removal and
testing of samples from all deer, elk and moose exhibiting clinical symptoms of
CWD, regardless of location, throughout the state.

The UDWR will reduce or maintain herd populations in CWD positive areas
below herd unit objectives. Hunting will be used as the primary management tool
to reduce deer and elk populations in units where CWD has been detected. All
herd reduction efforts will be coordinated with adjacent states where applicable.

The UDWR will look at policies to limit feeding of wildlife in areas where positive cases have
been identified and look at ways to reduce feeding programs in the state to reduce prevalence
and prevent transmission of CWD.

53

Chapter 4: Environmental Consequences

4.1 Introduction

In a standard environmental assessment, this chapter would compare the effects of each
alternative on the issues identified in section 1.9 of this document and on the relevant
resources that might be affected. In this environmental assessment, the environmental
consequences will be evaluated somewhat differently. First, the predicted environmental
consequences of finding CWD in Montana's free ranging deer and elk populations will be
evaluated in terms of its effect on the issues identified in section 1.9. That evaluation is
essentially an evaluation of the effects of alternative I, the no action alternative. Second,
the impact that implementation of alternatives II through VI would have on the
environmental resources and on the issues will be evaluated.

The ability of any of the alternatives presented in this evaluation to manage or eliminate
CWD from the free ranging deer and elk herds in Montana is difficult to predict. An
evaluation of the success of programs implemented in other states is premature, although
experiences in other states do provide some basis for predicting success of the alternatives.
It is the responsibility of the department, after reviewing scientific data and public input, to
determine which of the alternatives is the most logical and reasonable alternative to
implement. That determination must weigh the impacts of the management actions against
the impacts of CWD on the environment.

Each of the alternatives presented discuss methods for the prevention of CWD in Montana,
for CWD surveillance programs, for management of CWD once it is found in Montana, for
the dissemination of information to the public, and for research concerning CWD. The
public information plan is consistent throughout all of the alternatives and has been
provided in Appendix 1. Providing public information is a responsibility taken very
seriously by the department and only the most timely and efficient program was
considered for equal incorporation in each of the alternatives. Research on CWD is only
briefly discussed in each of the alternatives. Appropriate research projects will be closely
tied to the species, population density, and habitat parameters present where the disease
develops and can only be discussed in general terms because specific information on those
parameters is not currently known. In all cases, the research will include methods to
evaluate the success of any management action implemented. A CWD Task Force, made
up of wildlife biologists and wildlife disease experts, will evaluate management success
and any new scientific information concerning CWD. That Task Force will make annual
recommendations for any changes or modifications to the existing plan based on the best
science available.

4.2 Cumulative Impacts

Cumulative impacts are impacts on the environment that result from incremental impacts
of the action when added to other past, present, and future reasonably foreseeable actions.
Management action taken in alternatives II through VI would have some cumulative
impacts on the local area in which CWD is initially identified. They would be considered
cumulative as the management actions would be commitments to annual actions taken
until management goals are reached for each alternative. In most cases, this impact would

54

occur as a decrease in the overall deer and/or elk population in the area and accompanying
economic loss to the local economy from the decrease in big game and big game hunters in
the area. These localized short term economic losses must be compared to potential long
term losses that could occur if no management action were taken and CWD became
established in the deer and elk populations not only locally, but also state-wide.

Preventative actions taken in alternatives III, V, and VI, and to a lesser extent alternative
IV, could have cumulative financial impacts on taxidermists and meat cutters in Montana
over the years that the measures are in place. The preventative actions provide laws to
prohibit the import of carcass parts, including deer and elk heads, from other states.
Although that prohibition could negatively impact taxidermists who regularly process
trophies from out of state animals, the impact may be reduced because other states have
similar prohibitions. Therefore, many non-resident hunters harvesting an animal in
Montana would have their trophy mounted in Montana prior to return to their home state.
In the same regard, some meat cutters may lose business from resident hunters who have
harvested an animal from out of state and must have the animal either boned or processed
before bringing it back to Montana. Again, non-resident hunters who harvest an animal in
Montana may provide additional business to the local meat cutters if they live in a state
with similar prohibitions.

4.3 Irreversible and Irretrievable Commitments

An irretrievable commitment of a resource is one in which the resource or its use is lost for
a period of time whereas an irreversible commitment of a resource is one that cannot be
reversed. Management actions to reduce wildlife population densities or to eradicate
CWD in a particular area would represent an irretrievable commitment of a resource.
Although the resource (big game population) may be lost, or at lease reduced, for a period
of time, the overall effect would be to allow for a healthy return of the resource, either
through reproduction or immigration, in an environment not affected by CWD.

4.4 Environmental Consequences of CWD on Identified Issues (Alternative I: The No
Action Alternative)

4.4.1. Effect of CWD on Montana's Wild Deer and Elk Populations

CWD is unlike other diseases that affect wildlife populations. Most disease
agents, once they have established an infection in a susceptible host population,
have the ability to move through that population rapidly. In those cases,
outbreaks of the disease called epizootics may result in a high percentage of the
population being affected (high morbidity) and, depending on the disease agent, a
high percentage of death in the affected population (high mortality). In those
cases, predicted effects on overall populations may be easily determined for
diseases that are well understood.

CWD has an absolute mortality rate (100%) but does not produce a high rate of
infection (morbidity) over short periods of time due, presumably, to relatively
inefficient transmission and long incubation periods. In order to evaluate the
effects of CWD on cervid populations, scientists have developed computer
models. Those computer models are based on normal factors that affect

55

population dynamics in deer herds and what is known about CWD mortality, the
rate of transmission for CWD and the time it takes for an infected deer to begin
shedding the prion and infecting other animals. Model predictions indicate that
CWD can have significant impacts on cervid populations, but only over long
periods of time and only in situations where no management actions are
undertaken. Computer models of CWD have forecast declines in affected cervid
populations once the prevalence of CWD in a given population exceeds 5%
(Miller et al. 2000). If CWD is left unmanaged, models forecast that CWD
endemic regions such as northeastern Colorado or southeastern Wyoming could
experience CWD prevalence rates increasing 2- to 4-fold over the next several
decades with disease abating only with the extinction of infected deer populations
(Gross and Miller, 2001). Those predictions are based on a frequency-dependent
model where the number of contacts that an individual deer has with an infected
deer is constant and is not affected by changes in the density of the deer
population. (Figure 4)

Figure 5. From "CWD's impact on deer Herds", Chris Madson, Wyoming Game &
Fish Dept, 2003)

Model of deer herds

with chronic wasting disease

(an average of 250 simulations)

lOOO

_ sod -

CD

-g600

E

3 400

200

I Dee* In L.inLnf(:-(j.1trd

Denr ir% nfeoted
pa puteftions

I Intecltous dee-r In
I Infected populations

J i— L

20

40 60

Year

80

100

Arguments have also been presented for a density-dependent model for
transmission of CWD rather than a frequency dependent model (Schauber and
Woolf, 2003). In the density dependent model, the number of contacts between
deer would decrease as the density of the population decreased due to disease or
other mortality factors. If a reduced population density were eventually reached
that would not be sufficient to sustain continued transmission of the disease,
CWD could eventually "die out." The unknowns in this density-dependent model
include the role that environmental contamination may play in natural CWD
transmission, the movement or migration of infected individuals from a herd to

56

adjacent uninfected herds causing new outbreaks of infection, and the population
density required to sustain continued transmission of CWD.

The location of the initial CWD diagnosis in Montana and the affected cervid
species will have a great influence the overall impact of CWD. Montana's deer
herds have been divided into management units. Those management units include
the Northwest Montane, the Mountain Foothills, the Prairie/Mountain Foothills,
the Southern Mountains, and the Prairie Breaks. Depending on where CWD is
found, the population density of the local herds and their migratory patterns
within and out of those management units will influence the speed at which CWD
is able to move across the landscape. Differences in environmental characteristics
and population dynamics contributed to the definition of management units.
From the perspective of disease ecology, however, Montana's deer herds should
be considered as one continuous population. Geological or geographic barriers
may slow the spread of the disease, but without adequate prevention and
management, CWD may ultimately affect deer and/or elk throughout the state.
Whether computer models have correctly forecast potential impacts on overall
populations is yet to be determined.

4.4.2 Effects of CWD on Wildlife Management tools.

In 2001, almost 170,000 hunters took to the field during the Montana deer season
resulting in a harvest of almost 112,000 mule deer and white-tailed deer
combined. Similarly, over 100,000 elk hunters per year have participated in the
management of the elk population in recent years with annual harvests averaging
about 30,000 animals. In addition to providing a substantial economic impact to
Montana's local economies and funding MFWP efforts to manage big game
populations, those hunters have provided a vital tool for the management efforts
needed to maintain healthy big game populations within the boundaries of habitat
availability and social pressures. A reduction in numbers of hunters could have
significant impacts on the ability of FWP to manage big game populations in
Montana.

In 2002, license sales for the Wisconsin gun deer-hunting season declined
approximately 1 1% following the discovery of CWD in the state (Vaske, J.J. et al,
2004). Hunter surveys conducted in South Dakota (Gigliotti, L.M., 2004)
indicated that the prevalence of CWD in a particular hunting unit had a direct
influence on hunter participation in that unit. Survey results in 2003 indicated
that 59% of South Dakota hunters would change their hunting habits if only one
CWD positive deer was discovered in their deer-hunting unit. If the prevalence of
CWD in that hunting unit were 5%, however, 89% of the hunters indicated that
they would change their hunting habits. Whereas only 2% to 4% of hunters
indicated they would stop hunting deer in their unit if only one CWD positive
deer were found, 9% to 15% indicated they would stop hunting deer in their unit
if the prevalence of CWD were at 5%.

57

While the effect of CWD on resident hunter participation may be localized to
endemic areas or regions of a state where CWD has been diagnosed, non-resident
hunters indicated that they would be more likely to hunt in other states not
affected by CWD. All of these reactions to CWD by hunters are tied both to
CWD prevalence and to the perceived threat of CWD to human health. If
prevalence levels increase to 50% in a particular state, surveys have shown that
almost 50% of hunters will stop hunting in that state. Based on the findings from
South Dakota and Wisconsin, 60% to 68% of hunters will stop hunting deer/elk in
their state if prevalence level increases to 50% and CWD is shown to be
transmissible to humans or cause human death (Needham, M.D. et al, 2004).

In addition to the potential loss of hunters as a general wildlife management tool,
loss of hunter participation in regions of the state where CWD has been found
may affect the success of potential management actions. Many of the alternatives
described below enlist hunters to harvest animals from affected areas providing
CWD prevalence data. Hunter's involvement will also be important, when
possible, in the reduction of population densities in CWD affected areas. If there
is a reduction in hunter participation, responsibility to carry out management
actions may fall more with trained agency staff. Surveys have shown that the
public acceptability of using trained agency staff to take management actions as
opposed to using hunters is directly related to the prevalence of CWD in the
management area and the status of any CWD human health issues.

4.4.3 Effect of CWD on Montana's Economy

In 2002, elk license sales to Montana residents generated almost $1.9 million in
income to MFWP and non-resident elk license sales generated $11.7 million in
income to MFWP. This total of $13.6 million was about 53% of all license fees
received by MFWP and does not include elk permit drawing fees, archery license
fees, or conservation license fees not included in license packages. In 2002, total
deer license sales to residents and non-residents generated $5.2 million in license
fees. In addition, deer and elk hunters accounted for a large share of the $5.6
million in Federal Pittman-Robertson funds distributed to MFWP as a result of
federal excise taxes collected on the manufacture of rifles, handguns, ammunition,
and archery equipment. Thus, elk and deer hunting are of major importance in
direct funding to MFWP for conservation and management programs affecting
elk, deer and other wildlife species native to Montana.

Funding management programs for the prevention and control of CWD in
Montana would provide additional economic strain on MFWP. Wisconsin
reported an expenditure of $14.7 million in 2002-2003 fiscal year for combating
CWD. Of that $14.7 million, $12.6 million was spent by the Wisconsin
Department of Natural Resources, Wisconsin's equivalent of MFWP (Bishop,
2004). Currently, Montana's CWD surveillance program is being partially funded
through grants from USD A/APHIS that amounted to $89,000 for fiscal year 2005.
In addition, license fees received by MFWP funded approximately $26,000 for
the surveillance program and for providing public information concerning CWD.

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Finally, additional dollars have been appropriated from license fee funding for the
development of this CWD Action Plan. The monies currently appropriated from
license dollars or from USDA/APHIS for CWD surveillance and public
information will be inadequate should management actions be necessary for CWD
in Montana. If CWD is diagnosed in Montana, funding from USDA/APHIS
would increase from $89,000 to approximately $280,000, but additional funding
would be required either from legislative appropriations from the general fund,
from license dollars acquired through the sale of hunting and fishing licenses, or
through additional federal grant dollars. It is anticipated that the funding of CWD
management through appropriated license dollars would adversely impact other
programs at MFWP designed to manage and protect our wildlife resources.

In addition to providing funding to MFWP through the sale of hunting licenses,
the hunting and wildlife viewing industry in Montana are substantial contributors
to the state's overall economic output. In 2001, hunters spent an estimated $237.6
million in Montana (USDI, Fish and Wildlife Services and U.S. Department of
Commerce, U.S. Census Bureau 2003). Big game hunting accounted for about
80% of this total. Wildlife viewing provided an additional estimated expenditure
of $350 million. Thus, hunting and wildlife viewing accounted for an estimated
$589 million in expenditures in Montana. This expenditure was equivalent to
about 1.6% of the total economic output for Montana in 1999 (Minnesota
FVIPLAN Group, 2002). The amount spent on hunting and wildlife viewing
represents 23% of the economic output provided by farming, ranching, and
agricultural services combined in Montana in the same time period. Similar
comparisons are 62% of the combined economic output of all mining, 38% of the
output of the petroleum industry, and 32% of the combined output of forestry
products, wood products, and pulp and paper. All of these dollars provide a
"multiplier effect" as the dollars spent for lodging, fuel, sporting goods,
equipment, etc. are then used to provide jobs and income to local communities
where the dollars generated are again turned over to purchase more local goods
and services.

Information generated in Wisconsin during the 2002 and 2003 hunting seasons
indicated a 9.9% reduction in hunters in 2002 (the year of the initial CWD
diagnosis in Wisconsin) and a 5.9% reduction in 2003. The slight increase in
hunters between 2002 and 2003 was most likely the result of surveillance efforts
conducted in 2002 and assurance to hunters that CWD was limited to a few
southern counties (Bishop, Richard C, 2004). Although only 6% of Wisconsin
hunters were non-residents, there was a 19% decrease in the number of non-
resident hunters in 2002. In evaluating Wisconsin's economic losses due to CWD
concerns, Bishop pointed out that, although he estimated a $55 million loss to
Wisconsin due to CWD, most of that loss was not removed from the Wisconsin
economy since Wisconsin's predominantly resident hunters probably spent their
hunting dollars on other commodities in Wisconsin. Approximately 16% of
Montana big game hunters are non-residents. If, Montana lost 19% of those non-
resident hunters as Wisconsin did, the economic impact would be significant. The

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economic contributions to Montana retail sales from non-resident hunter of all
types was estimated at $85 million in 2001 (IAFWA, 2001). After applying an
economic multiplier effect to those dollars, the impact is estimated at $157
million to Montana's economy. Non-resident deer and elk hunters generated
much of that $157 million. A loss of 19% of those non-resident hunters would
amount to an impact of between $20 and $30 million.

Resident hunters in Montana make up approximately 85% of the total hunter
numbers. Of the $237.6 million dollars generated in 2001 by hunting related
activities in Montana, a large portion of that was money spent by resident hunters
in local economies. Although those dollars may be redistributed to other
expenditures and not lost to the total Montana economic output if CWD were
diagnosed in Montana, that redistribution could have significant impacts on local
economies. Many businesses in those local economies depend heavily on the big
game hunting season to supply a substantial portion of their annual incomes.

4.4.4 Effect of CWD on the Alternative Livestock Industry

MFWP currently licenses 61 alternative livestock ranches (game farms) in
Montana. Those licensed facilities reported an inventory of 2,582 animals in their
December, 2004 inventory reports to the department. Elk are farmed for breeding
stock, velvet antler production, meat production, and sale to out of state "game
parks" for the harvest of trophy bulls.

Nationwide, the National Elk Breeders Association has estimated that there are
150,000 elk on 2,300 U.S. alternative livestock ranches. Based on an estimated
average value of $2500 per elk, the value of all 150,000 elk on U.S. farms is $375
million. In 1999, gross receipts for the elk farming and velvet antler industry in
North America totaled an estimated $150 million (USD A/ APHIS, 2003). CWD
has, however, had a significant impact on the economy of the alternative livestock
industry since 1999. CWD was first found in an alternative livestock herd in
South Dakota in 1997. Since that time, CWD has been found in additional farmed
cervid herds in South Dakota, Colorado, Nebraska, Montana, Wisconsin, Kansas,
Oklahoma, Minnesota, and New York. The finding of CWD either in captive or
free ranging cervids has prompted at least 23 states to ban the import of cervids.
In addition, the Republic of Korea has suspended all imports of deer and elk, and
their products, including velvet antler, from the United States. While it is difficult
to determine the economic loss in the U.S. from the sale of velvet antler to Korea,
Canada did show an 80% drop in their CA$13 million sale of velvet antler to
Korea the year after CWD was introduced into Korea from Saskatchewan
(Saskatchewan Agriculture and Food, 2000). Likewise, the ban on the import of
animals has reduced the market size and corresponding market value for breeding
stock sales economically affecting the alternative livestock industry.

Economic impacts of CWD to the alternative livestock industry result not only
from the loss of market value of the animals and their products, but also from the
expenses incurred by alternative livestock ranchers to participate in state and

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federal programs required for the control of CWD. Currently, any alternative
livestock animal in Montana that dies and is 16 months of age or older must be
tested for CWD. Since the program was initiated in April of 1999, over 3500
animals have been tested for CWD. The cost for that testing, has amounted to
approximately $525,000 (3500 X estimated cost of $150 per test) or $87,500 per
year, and is paid by the alternative livestock rancher. In addition, the CWD
testing program requires that an annual inventory be conducted on each
alternative livestock herd by a D.V.M. certified by the state of Montana as a
"designated agent" of the Department of Livestock (DoL). Ear tags on all
alternative livestock must be read and the final inventory verified against
department records. Those inventory costs, estimated at $1000 per herd, would
amount to an additional $61,000 (61 facilities X $1000) per year paid by the
alternative livestock industry. Using the above figures, a direct cost of $148,500
per year is spent by the industry, or an average of approximately $2435 per
alternative livestock licensee ($148,500/61), to comply with the CWD program
currently in place in the state of Montana. When including indirect costs,
USD A/ APHIS has estimated the cost to the producer of participation in a CWD
program at $12,350 a year for an average herd of 50 animals (USDA/APHIS,
2001)

The diagnosis of CWD either in an alternative livestock herd or in a wildlife
population in close proximity to a captive herd would result in the quarantine of
that facility by the DoL. DoL would develop a "herd plan," in cooperation with
the alternative livestock licensee. One outcome of that herd plan could be
depopulation of the animals to allow for CWD testing. In the event of
depopulation and subsequent testing for CWD, USDA/APHIS has provided an
indemnity payment to the licensee to compensate for the lost animal. The
USDA/APHIS indemnity program, established through an interim rule in
February, 2002 provided payment to the licensee at a rate of 95% of the appraised
value of the animals up to a maximum of $3000 per animal. That interim rule is
expected to be finalized in September of 2005. Those indemnity payments
require depopulation of the entire captive cervid herd determined to be CWD
exposed and no restocking on the affected premises with cervids without APHIS
approval. Other costs involved with the killing, testing, and disposal of the
alternative livestock would be evaluated and distributed on a case-by-case basis.
The developed herd plan may also restrict the rancher as to what animals may be
kept on what had been captive cervid pastures for a long period of time resulting
in further economic loss to the licensee. In the one instance where a Montana
alternative livestock licensee was faced with the diagnosis of CWD in his herd, a
total of 87 animals were "depopulated." Although the herd plan included a
requirement that cervids not be allowed on that land for a minimum of 2 years, the
former licensee has since opted to relinquish his alternative livestock license and
not to restock the facility with captive cervids.

If an operator did not opt for depopulation of CWD exposed animals, the other
option would be a state-imposed quarantine lasting for several years. Quarantine

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of the animals would require that the facility have a double fence to restrict any
direct contact with domestic livestock or with free-ranging wildlife. Under
quarantine conditions, the licensee would not be able to sell or move live animals
from the facility severely limiting any economic opportunities.

4.4.5 Effect of CWD on Human Health

The prion thought to cause CWD has not been shown to affect humans. The
perception of risk from CWD due to the association that has been tentatively
established between mad cow disease, a domestic animal TSE, and variant
Creutzfeldt-Jakob Disease (vCJD), a human TSE, has caused public concern and
heightened public awareness of TSE diseases. There have been numerous reports
by the media of big game hunters who have developed CJD. These reports, for
the most part, have not identified the disease diagnosed in the humans as sporadic
CJD or variant CJD. As a result of the media reports, studies have been
conducted by the Center for Disease Control (CDC) to evaluate the risk of CWD
to hunters or to those consuming venison. In all cases, a causal relationship, such
as a food-born link between CWD and a human illness, could not be identified.
Additionally, even though CWD has been endemic in Colorado and Wyoming for
decades, the incidence of sporadic CJD and the age distribution of sporadic CJD
case-patients in those two states is similar to that seen in other parts of the United
States (Belay, et. al., 2004). There has only been one case of vCJD reported in
the United States. That case involved a female patient in Florida that had been
exposed to the BSE agent in the United Kingdom prior to moving to the United
States. Studies done by CDC to this point have not identified a link between
CWD and any form of prion disease in humans.

Although there is no scientific evidence to implicate CWD in any form of human
illness, it is anticipated that the finding of CWD in wildlife populations will raise
new concerns among the public. Based on the results of surveillance studies
carried out in deer and elk in Montana since 1998, there is no known human
exposure to the CWD prion agent in Montana due to handling or consumption of
free-ranging deer or elk or tissues at this time. Many hunters may decide that
irregardless of current scientific information, they will not hunt big game in
particular areas of Montana, or anywhere in Montana, if CWD is diagnosed in
Montana free-ranging deer and/or elk.

4.4.6 Effect of CWD on Environmental Contamination and Carcass Disposal

The role that environmental contamination plays in the transmission and
epidemiology of CWD remains unclear. There is concern, however, that indirect
natural transmission of CWD could occur through contamination of the
environment by excretions, secretions, or the decomposition of infected animal
carcasses. (USDA/ APHIS, 2002) Studies recently completed in Colorado have
provided new information concerning environmental contamination. In one
study, CWD negative animals placed in a pen that had contained CWD infected
animals 2.2 years earlier eventually developed CWD as a result of the
environmental exposure. In a second study, CWD uninfected deer developed

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CWD following exposure to carcasses of CWD infected deer that had been placed
in pens 1.8 years earlier and allowed to decompose. These findings indicate that,
"environmental sources of CWD infection represent potential obstacles to control
in natural and captive settings" (Miller, et al. 2004).

Even before the Colorado study, many states had imposed carcass import
restrictions limiting importation of heads and spinal cords from deer and elk
harvested in other states. Dr. Mike Miller, the author of the study, has indicated
that the implications of the Colorado environmental studies must, however, be
taken in context concerning the spread of CWD via parts from harvested animals.
First, the infective material used as the "contaminant" in these studies originated
from animals that were either in the end stages of CWD or had died of CWD. In
the wild, the majority of CWD infected animals harvested would not be showing
clinical symptoms and would conceivably not have the concentration of abnormal
prion in the nervous tissue and lymph tissue that the study sources did. Viscera
and other wastes left in the field by hunters harvesting normal appearing animals,
even if they had been infected with CWD, would provide much less of an
"infective dose" than that provided by the study animals as would the brains and
spinal cords of harvested animals brought home or to the meat processor. Second,
the experimental animals in the Colorado study were confined in relatively small
pens where repeated exposure to the contaminated material was more likely to
occur than would be expected on the open ranges.

Nevertheless, animals dying in the wild from CWD would have the capacity to
transmit CWD to non-infected herd mates. If environmental CWD exposure does
turn out to be an important aspect of natural CWD transmission in the wild, the
disease may be expected to sustain itself in the face of eradication attempts that do
not involve attempts to remove animal carcasses from the landscape. In addition,
carcass remnants from harvested animals could provide an additional source of
contamination if proper disposal methods are not utilized. The finding of CWD in
Montana's wildlife populations may, therefore, precipitate some changes in
carcass disposal requirements in Montana. Those requirements would be
expected to decrease the possibility for the spread of CWD. Without a definite
management plan, the form those requirements may take is difficult to predict.

4.5 Predicted Environmental Impacts of Alternative II - Under alternative II,

MFWP would expand the current surveillance program to provide for a statewide
coverage. Surveillance area boundaries would be established as MFWP regional
boundaries with a goal of detection of a 1% incidence of CWD on a regional basis with a
99% confidence. No additional preventative requirements would be put in place.
Management of CWD would be attempted through increased harvest quotas in affected
areas intended to reduce the population density, the number of animal contacts, and thus
the spread of CWD. An affected area would be defined based on any geologic or
geographic barriers that would help to delineate a population. Movement of carcass parts
(heads and spinal cords) out of the affected area would be prohibited.

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4.5.1 Biological Environment
Deer and Elk Populations

Increased surveillance for CWD under alternative II would be accomplished by
establishing additional check stations across the state. No direct environmental
impacts are anticipated through increased surveillance. Increased surveillance
would provide a better understanding of the CWD status of deer and elk
throughout Montana and could potentially identify "hot spots" of disease earlier.
An increase in harvest quotas in the "affected area" would reduce the local
deer/elk populations and the potential for transmission of CWD while providing
data for the prevalence of CWD in the affected area. This reduction in population
through increased harvest quotas would be temporary and would be monitored
annually to evaluate changes in the population and changes in prevalence of the
disease. Overall statewide populations would not be negatively affected but could
benefit if CWD were eliminated or contained in the management area.

Other Wildlife Populations

Local effects on other species are unknown. Any large predators in a
management zone would be expected to be affected by decreases in the cervid
population. Those predators may substitute other prey sources or leave the area.
Scavenger populations would be expected to show a temporary increase due to the
increase in viscera left behind from increased harvests. There is no indication at
this time that scavenger or predator species can be "infected" by CWD. Any
effect on endangered species would be evaluated depending on the population of
endangered species, if any, in the area.

Wildlife Management Tools

Based on surveys done in other states where CWD has been detected, hunter
participation is inversely related to the prevalence of CWD in an area and to the
current information available on the transmission of CWD to humans. Some
decrease in hunter participation in the management area would be expected. This
decrease in participation could be mitigated through incentives given to hunters to
harvest animals in the affected area.

4.5.2 Physical Environment
Soil

Alternative II does not increase preventative measures and thus does not reduce
the potential for importation of CWD contaminated carcasses or the potential for
improper disposal of carcasses from animals harvested within or outside of
Montana. Contamination of soil with prions could be an issue, although the
importance of that issue in the natural transmission of CWD is not fully
understood at this time. A prohibition on the removal of contaminated carcasses
or of heads and spinal cords from the management area would reduce the
potential for contamination of soils outside of the management zone with CWD.

Water

See section on soil.

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Air

Management actions in a defined area would require that no heads or spinal cords
from animals harvested in that area be allowed to leave. Incineration of those
carcass parts would be required using a state-owned portable incinerator. There
would be minimal effect on the air due to the incineration of those carcass parts
and that effect would be localized and short lived.

4.5.3 Socioeconomic Environment
Alternative Livestock Industry

No direct effects are anticipated through the enactment of management actions
included in Alternative II. If there is an alternative livestock facility within the
home ranges of free ranging cervids in the affected area, it would be expected that
DoL would take appropriate actions to assure the safety of the rest of Montana' s
alternative livestock industry. Those actions may include a facility quarantine and
accompanying herd plan.

Economy

The effect of CWD on Montana's economy has been discussed previously in
section 4.4.3. Alternative II would be expected to have a short-term positive
effect on the local economy as increased harvest took place over the years. That
positive effect may be reduced if the management plan is successful in reducing
local big game populations but would rebound if CWD is eradicated or kept at
low levels and an uninfected population rebounds.

Human Health

No human health implications would be expected with the implementation of
alternative II. The public would be kept informed of the CWD status in Montana
cervids and of any developments in prion science that might affect human health.

4.6 Predicted Environmental Impacts of Alternative III - Under alternative III, MFWP
would enhance the prevention program for CWD through the development of laws and
regulations prohibiting baiting and feeding, translocation of wild cervids, and transport of
cervid carcasses. The surveillance program would focus on high-risk areas, targeted
samples, enhancement of road-kill collection, and surveillance in a management zone. A
management program would attempt to establish buffer zones around the affected area to
decrease immigration and emigration of cervids.
4.6.1 Biological Environment
Deer and Elk Populations

Depending on the geological and geographical nature of the identified
management zone, increased harvest quotas may be necessary to establish a buffer
zone around the affected area. These increased harvests would be focused on the
periphery of the management zone to attempt to contain movement out of the
management zone by potentially infected cervids. Due to the long incubation
period of CWD in cervids and to the relatively low rate of transmission, a
commitment would be needed to maintain the buffer zone for many years as the

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disease developed within the management zone. If a buffer could be adequately
established and maintained, the "closed population" within the buffer zone could
afford unique opportunities to study the epidemiology of CWD in a closed
population.

Increased harvests would have impacts on local cervid populations by reducing
the numbers of animals in the buffer area. As mentioned, this population
reduction would need to be maintained until CWD was no longer present inside
the buffer zone for the management action to be successful.

Other Wildlife Populations

Increased harvest in the buffer zone may attract more scavengers to the area.
Depending on the mortality rate in cervids within the management zone from
CWD, increased predators and/or scavengers may be attracted. Effects on
endangered species would be evaluated on a location-by-location basis.

Wildlife Management Tools

Hunter participation is expected to depend on the prevalence of CWD in the
management zone and on the perceived danger of CWD to humans. Cervids from
the buffer zone would be expected to have a lower prevalence of CWD than those
animals within the management zone. If CWD remains localized to the
management zone and, at a lesser prevalence, the buffer zone, hunter participation
statewide should be affected little while decreased participation in the
management and buffer zones could be expected. Hunter incentives may be
required to achieve buffer maintenance.

4.6.2 Physical Environment
Soil

Enhanced preventative measures incorporated into alternative III could reduce
potential contamination of the soil with CWD prions by prohibiting the import of
carcasses from other states and by requiring proper disposal of carcasses
harvested in Montana.

Water

See section on soil.

Air

Movement out of the buffer zone or management zone of heads and spinal cords
of harvested animals would be prohibited. Disposal of those heads and spinal
cords may be achieved on site through incineration using a state-owned portable
incinerator. There would be minimal effect on the air from this high temperature
incinerator.

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4.6.3 Socioeconomic Environment
Alternative Livestock Industry

Alternative III would have no direct effects on the alternative livestock industry
unless a facility were located within the buffer zone or management zone. In
those cases, DoL would take appropriate action to protect the alternative livestock
industry in Montana by potentially quarantining the affected herd and requiring a
herd plan.

Economy

Active maintenance of a buffer zone would require either department personnel or
hunter involvement over many years. That activity could initially be a boost to
local economies in the affected area. Should hunter participation due to the
discovery of CWD in the area be reduced, however, a detrimental impact to local
economies may be expected.

Increased preventative measures associated with alternative III would prohibit the
import of carcass parts from other states and require that meat brought into
Montana be either processed or boned out. Meat processors may lose a portion of
their business from customers harvesting big game out of state and returning to
Montana. On the other hand, non-resident hunters who harvest animals in
Montana, depending on their state of residence, may have to bone out or process
meat prior to their return home thus adding business to Montana meat processors.
Increased preventative measures will have the same effects on Montana
taxidermists. Taxidermists may lose the business of Montana hunters who harvest
animals in other states, but will gain some business from non-resident hunters that
harvest big game in Montana.

Finally, outfitters whose operation plans include lands on which management
actions will be taken may find it difficult to attract clients to the area. Both the
prevalence of CWD in the area and the current scientific knowledge concerning
the transmission of CWD to humans will determine the amount of business that
may be lost by the outfitters. Every attempt will be made by the department to
enlist the outfitters and clients in an affected area in reducing populations in the
buffer zone or the management zone. Eventual reduction of populations through
buffer maintenance may reduce the attractiveness of the immediate area and
reduce marketing potential to outfitter clients.

Human Health

No human health implications would be expected with the activation of
alternative III. The public would be kept informed of the CWD status in Montana
cervids and of any advances in the field of prion research.

4.7 Predicted Environmental Impacts of Alternative IV - Under alternative IV, MFWP
would increase preventative measures through laws or policy to curtail baiting and feeding
of cervids and the translocation or transplantation of cervids in Montana. Carcass
transport would not be prohibited, but an educational program to influence hunters not to

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bring specific carcass parts back into Montana from other states would be developed.
Surveillance would focus on high-risk areas with regionally intensive surveillance in
management zones. The collection of road-kill and targeted samples would continue.
Disease management would require a determination of the population "range" of the
affected population by radio-collaring 50 animals of the affected species and monitoring
them through radio-telemetry for a season. Then, based on the determined range and
estimated population within that range, a statistical sample to allow for detection at 1%
incidence with a 99% confidence interval would be collected from that population.
Repeated statistical sampling would continue until a result of <1% incidence were
achieved.

4.7.1 Biological Environment
Deer and Elk Populations

Management actions under alternative IV are designed to provide additional
surveillance data and to reduce the population density in the affected area.
Sample size required to monitor for prevalence would depend on total population
estimates, but an estimated population of 2000 animals, for example, would
require samples from over 400 animals, or 20% of the total population. If those
samples resulted in a CWD incidence of >1%, the management plan would call
for an additional statistical sample of the remaining population resulting in further
population reduction. Repeated sampling in an area until reaching the <1%
incidence goal could result in a substantial reduction of cervid numbers from the
management zone. It is predicted that the population reduction would help to
either eliminate CWD or to slow the transmission of CWD resulting in short term
local population reductions followed in 5-10 years by the rebound of a healthy
population while providing protection to other cervid populations in Montana.

If CWD were found during sampling at a level of >5%, an immediate 50%
reduction in cervid population would be carried out. Depending on the CWD
prevalence found in the samples collected from the population reduction,
additional statistical samples may be collected until the prevalence in a sequential
statistical sample is found to be <1%. Based on this scenario, an even more
substantial reduction in population density would take place within the identified
population. Effects would, however, be limited to the local population and would
provide protection for other cervid populations in Montana.

Other Wildlife Populations

Any large predators in a management zone would be significantly affected by the
cervid population decreases. Those predators would be expected to substitute
other prey sources or to leave the area. Scavenger populations would be expected
to show a temporary increase due to the increase in viscera left behind from
sampling operations. Any effects on endangered species would be evaluated
depending on the area of the management action.

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Wildlife Management Tools

Again, the determined prevalence of CWD and the current scientific information
concerning human risk will greatly influence the participation of hunters in a
CWD endemic area. Hunter participation would be expected to decline in the
management area with hunter incentives necessary to achieve the required
harvests. It is anticipated that the harvest of even the first required statistical
sample from an area may partially require the participation of department staff to
achieve the sample goals.

Actively combating CWD, providing information on CWD prevalence in the area,
and providing current surveillance data statewide should help to maintain the
hunter participation on a statewide basis.

4.7.2 Physical Environment
Soil

Policy changes and educational programs should reduce the improper disposal of
carcass parts and therefore any potential contamination of soil by prions.

Water

See section on soil.

Air

Prohibitions on the movement of heads and spinal cords from harvested animals
out of the management zone would require incineration of those carcass parts on
site. There would be minimum and only temporary impacts to the air quality by
emissions from the incinerator.

4.7.3 Socioeconomic Environment
Alternative Livestock Industry

Management actions of alternative IV would have little impact on the alternative
livestock industry. If an alternative livestock facility were located within the
designated management zone, however, DoL would take appropriate action to
protect the alternative livestock industry in Montana by potentially quarantining
the affected herd and requiring a herd plan.

Economy

Under alternative IV, management actions would remove a statistical sample, and
perhaps consecutive statistical samples, of cervids from the management zone.
These sampling actions would provide short-term economic benefits to the local
area due to an increase in hunters and/or department staff involved in the
sampling effort. In the long term, however, a significant population reduction
would be achieved in the management zone. Depending on the size of that
management zone, adverse economic impacts may occur due to the loss of hunter
dollars. In addition, finding CWD in the area may detract from the number of big
game hunters that come to the area.

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Although alternative IV would not prohibit carcass import by law, anticipated
compliance with the preventative aspects of the alternative due to effective
education programs concerning carcass import would result in a potential loss of
income to local taxidermists and meat processors. That loss should be overcome,
however, due to similar prohibitions by other states that would require non-
residents harvesting cervids in Montana to have their taxidermy work completed
in Montana or have their meat processed in Montana prior to returning to their
state of residence.

Finally, outfitters whose operation plans include lands on which management
actions will be taken may find it difficult to attract clients to the area. Both the
prevalence of CWD in the area and the current scientific knowledge concerning
the transmission of CWD to humans will determine the amount of business that
may be lost by the outfitters. Every attempt will be made by the department to
enlist the outfitters and clients in an affected area in reducing populations in the
management zone. Eventual reduction of populations may reduce the
attractiveness of the immediate area and reduce marketing potential to outfitter
clients.

Human Health

Same as alternative III.

4.8 Predicted Environmental Impacts of Alternative V - Like alternative IV, alternative V
first determines a cervid population's yearlong distribution, estimates a population
number, and then requires a statistical sample to detect a 1% incidence of CWD at a 99%
confidence interval. Alternative V differs from alternative IV in that consecutive statistical
sampling would continue until a result of 0% CWD detection rather than <1% in the
sampled population was achieved. The predicted environmental impacts are therefore the
same but with the potential to be slightly more severe. Alternative V also establishes laws
and regulations for CWD prevention issues rather than employing public information and
education or policy changes.

4.8.1 Biological Environment
Deer and Elk Populations

Populations of deer or elk within the management zone would be impacted due to
implementation of this alternative. Depending on the prevalence of CWD in the
population, repeated statistical samples might be required to achieve the goal of 0%
detection from a sample capable of detecting a 1% incidence with a confidence
interval of 99%. Repeated statistical samples could, in the short term, drastically
reduce and potentially eliminate a cervid population within the management zone.
That effect would be short term with repopulation of the area expected within 5-10
years. The management action is predicted to either eliminate CWD from the area
or significantly reduce the opportunity for spread of the disease to other cervid
populations in Montana.

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Finally, outfitters whose operation plans include lands on which management
actions will be taken may find it difficult to attract clients to the area. Both the
prevalence of CWD in the area and the current scientific knowledge concerning the
transmission of CWD to humans will determine the amount of business that may be
lost by the outfitters. Every attempt will be made by the department to enlist the
outfitters and clients in an affected area in reducing populations in the management
zone. Eventual reduction of populations may reduce the attractiveness of the
immediate area and reduce marketing potential to outfitter clients.

Other Wildlife Populations

Same as alternative IV.

Wildlife Management Tools

Same as alternative IV.

4.8.2 Physical Environment

Due to the similarities between alternatives IV and V, the predicted environmental
impacts on the physical environment for alternative V are the same as those
described for alternative IV.

4.8.3 Socioeconomic Environment
Alternative Livestock

Same as alternative IV

Economy

The predicted economic impacts for alternative V are similar to those for alternative
IV. One exception is the potential for a more severe economic impact in the local
area. A more extensive population reduction in the management zone would
require more initial public and/or department involvement that may provide a short
term benefit to the local economy. The eventual population reduction would,
however, have a detrimental economic impact on the hunting dollars put into the
local economy until the cervid population recovered to normal levels. That
recovery could take 5-10 years depending on the quality of habitat available in the
management zone.

As with the other alternatives that establish laws and regulations prohibiting carcass
transport, taxidermists and meat processors may lose business from residents that
leave Montana to harvest deer or elk. That loss should be overcome, however, due
to similar prohibitions by other states that would require non-residents harvesting
cervids in Montana to have their taxidermy work and meat processing done locally
before returning to their state of origin.

Finally, outfitters whose operation plans include lands on which management
actions will be taken may find it difficult to attract clients to the area. Both the
prevalence of CWD in the area and the current scientific knowledge concerning the
transmission of CWD to humans will determine the amount of business that may be

71

lost by the outfitters. Every attempt will be made by the department to enlist the
outfitters and clients in an affected area in reducing populations in the management
zone. Eventual reduction of populations may reduce the attractiveness of the
immediate area and reduce marketing potential to outfitter clients.

Human Health

Same as alternative III.

4.9 Predicted Environmental Impacts of Alternative VI - Alternative VI represents the
most aggressive alternative. Preventative measures would be required by law, surveillance
would be statewide, and management would involve development of an "eradication zone"
in which attempts would be made to kill and test all cervids.

4.9.1 Biological Environment
Deer and Elk Populations

Under alternative VI, deer and elk populations within the management zone would
be eliminated to the greatest extent possible. The size of the management zone
would depend on what is known about the home ranges of resident populations,
geographic and geologic barriers, as well as access issues on privately owned lands.
As a point of reference, a management zone with a 5-mile radius would encompass
approximately 80 square miles and contain 400 animals if there were 5 deer per
square mile. Eliminating 400 animals would definitely have a local effect on the
cervid population but, if successful in eliminating this initial "hot spot" of CWD,
would protect other cervid populations in Montana.

Other Wildlife Populations

Same as alternative IV

Wildlife Management Tools

Same as alternative IV.

4.9.2 Physical Environment
Soil

Laws and regulations would greatly reduce the improper disposal of carcass parts
and therefore any potential contamination of soil by prions.

Water

See section on soil.

Air

Prohibitions on the movement of heads and spinal cords from harvested animals out
of the management zone would require incineration of those carcass parts on site.
There would be minimum and only temporary impacts to the air quality by
emissions from the incinerator.

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4.9.3 Socioeconomic Environment
Alternative Livestock Industry

Same as alternative IV

Economy

As is true with the less aggressive management plans, initial operations could
provide some positive economic effects to the local economy. Elimination of
cervids from the management zone would, however, create a negative economic
impact. In addition, the stigma of having a CWD management zone in an area
would likely reduce hunter participation in surrounding areas causing further
economic impact in the local economy.

Finally, outfitters whose operation plans include lands on which management
actions will be taken may find it difficult to attract clients to the area. Both the
prevalence of CWD in the area and the current scientific knowledge concerning the
transmission of CWD to humans will determine the amount of business that may be
lost by the outfitters. Every attempt will be made by the department to enlist the
outfitters and clients in an affected area in reducing populations in the management
zone. Eventual reduction of populations may reduce the attractiveness of the
immediate area and reduce marketing potential to outfitter clients.

Human Health

Same as alternative III

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Chapter 5: List of Individuals Associated with the Project

Chronic Wasting Disease Oversight Committee:

Tim Feldner

Manager, Commercial Wildlife Permitting, Montana FWP
CWD Project Coordinator, Compiler

Ron Aasheim Con Ed Administrator, Montana FWP

Neil Anderson Wildlife Laboratory Supervisor, Montana FWP

Dr. Mark Atkinson Wildlife Veterinarian, Montana FWP

Keith Aune Research and Technical Services Section Chief, Montana FWP

Gary Dusek Wildlife Biologist, Montana FWP

Dr. Kammy Johnson Epidemiologist, Montana DPFIHS

Dr. Tom Linfield State Veterinarian, Montana DoL

David Pac Wildlife Biologist, Montana FWP

Chris Smith Chief of Staff, Montana FWP

Evaleen Starkel Alternative Livestock Program Specialist, Montana DoL

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Chapter 6: List of Persons and Agencies Consulted

Montana Fish, Wildlife and Parks

All Regional Wildlife Managers

All Warden Captains

Jeff Herbert

Don Childress

Gary Hammond

Jack Lynch

Rob Brooks

Jim Kropp

Dianne Tipton

Tom Palmer

Jennifer Pelej

Andrew McKean

Patti Buckingham

Brian Sommers

Other Individuals or Groups Consulted or Contacted
Montana Wildlife Federation
Montana Taxidermists Association
Montana Meat Processors Association
Montana Veterinary Medical Association
Prickly Pear Sportsmen Association

Kathy Green
Rick Thompson
Wayne Johnson
Hank Edwards
Steve Griffin
Leslee McFarlane
Dr. Bruce Morrison
Dr. Mike Miller
Dr. Phil Maumer
Dr. Richard Mackie
Jacquie Ermer
Don McKinnon
P.J. White
Kevin Callele
Dr. Simon Hollamby
Joseph Brusca
Rebecca Mesaros
Dr. William Hadlow
Dr. Rick Race
Dr. Byron Caughy
Dr. Tom Roffe

Colorado Division of Wildlife

Montana DEQ (Waste Management Bureau)

Montana Board of Outfitters

Wyoming Game & Fish

South Dakota Game, Fish & Parks

Utah Division of Wildlife Resources

Nebraska Game & Parks

Colorado Division of Wildlife

Idaho Fish & Game

Montana FWP (retired)

North Dakota Game & Fish

Saskatchewan Environment, Fish & Wildlife Branch

National Park Service

Saskatchewan Environment, Fish & Wildlife Branch

Wisconsin DNR

Wisconsin DNR

Montana Alternative Livestock Producers

Rocky Mountain Laboratories (retired)

Rocky Mountain Laboratories

Rocky Mountain Laboratories

U.S. Fish & Wildlife Service

75

BIBLIOGRAPHY

Anderson, N., and K. Aune. (2004). CWD surveillance 1998-2003. Montana Fish, Wildlife and
Parks Unpublished Report. 1 1 pp.

Bartelt, G., Pardee, J., & Thiede, K. (2003). Environmental impact statement on rules to
eradicate chronic wasting disease from Wisconsin's free-ranging white-tailed deer herd.
Wisconsin Department of Natural Resources.

Belay E.D. (1999). Transmissible spongiform encephalopathies in humans. Annual Review of
Microbiology. 53,283-314.

Belay, E.D., Maddox, R.A., Williams, E.S., Miller, M.W. Gambetti, P., Schonberger, L.B.
(2004). Chronic wasting disease of deer and elk and the species barrier. Emerging Infectious
Diseases, 10(6)- 1082.

Bishop, Richard C. (2004) The economic impact of chronic wasting disease (CWD) in
Wisconsin. Human Dimensions of Wildlife. 9(3), 181-192.

Coon, T.G., et. al. (1999). Farming captive cervids in Michigan: a review of social, economic,
ecological, and agricultural opportunities and risks. Michigan State University Department of
Fisheries and Wildlife. 1 10 pp.

Center for Disease Control. (2004). Fact sheet: New variant Creutzfeldt- Jakob Disease.

Dunkley, L., and M. R. L. Cattet. (2003). A comprehensive review of the ecological and human
social effects of artificial feeding and baiting of wildlife. Canadian Cooperative Wildlife Health
Centre, Department of Veterinary Pathology, University of Saskatchewan, CANADA, (available
at: http://wildlife.usask.ca/english/CCWHCFeedingBaitingReportFinal Feb2003 .pdf )

FDA, Center for Veterinary Medicine. (2002). Material from CWD positive animals should not
be used for animal feed.

Gigliotti, Larry M. (2004). Hunters' concerns about chronic wasting disease in South Dakota.
Human Dimensions of Wildlife. 9(3), 233-239.

Hamlin, K.L. and M.S., Ross. (2002) Effects of hunting regulation changes on elk and hunters
in the Gravelly-Snowcrest mountains, Montana. Montana FWP, Helena.

Henderson, R.E., BA. Sterling, and T.O. Lemke. (1993) The lower Clark Fork elk study: Final
report 1985-1990. Montana FWP.

International Association of Fish and Wildlife Agencies. (2001). Economic Importance of
Hunting in America.

76

Macke, Richard J., David F. Pac, Kenneth L. Hamlin, and Gary Dusek. (1998). Ecology and
management of mule Deer and white-tailed deer in Montana. Report from the Montana
Department of Fish, Wildlife & Parks.

Miller, W.M., E.S. Williams, C.W. McCarty, T.R Spraker, T.J. Kreeger, C.T. Larsen, E.T.
Thorne. (2000). Epizootiology of Chronic wasting disease in free-ranging cervids in Colorado
and Wyoming. J. Wildl. Manag. 36(4), 676-690.

Miller, Michael W., E.S. Williams, N. Thompson Hobbs, L.L. Wolfe. (2004). Environmental
sources of prion transmission in mule deer. Emerg. Infect. Dis. 10. 1003-1006.

Minnesota IMPLAN Group. 2002. State Level Data - 1999.

Montana Department of Fish, Wildlife & Parks. (2001) Adaptive Harvest Management. January
15,2001.

Mundinger, J. and B. Beck. (2000). Alternative Livestock Program Evaluation. Consulting for
Creative Solutions, L.L.C. and Beck Consulting. Helena, Mt.

Mussehl, T.W., and F. W. Howell. (1971). Game Management in Montana Fed. Aid Proj. W-3-
C. Montana Fish and Game Dept.

Needham, Mark D. J. J. Vaske, M.J. Manfredo. (2004). Hunters' behavior and acceptance of
management actions related to chronic wasting disease in eight states. Human Dimensions of
Wildlife. 9(3), 211-231.

Saskatchewan Agriculture and Food. (2000) Elk production: economic and production
information for Saskatchewan producers.

U.S. Department of Agriculture, Animal and Plant Health Inspection Service (USDA/ APHIS).
(2001). Base line estimates of costs to state governments and to elk producers of chronic
wasting disease eradication effects.

U.S. Department of Agriculture, Animal and Plant Health Inspection Service (USDA/ APHIS).
(2002). Plan for assisting states, federal agencies and tribes in managing chronic wasting disease
in wild and captive cervids.

U.S. Department of Agriculture, Animal and Plant Health Inspection Service (USDA/ APHIS).
(2003). Chronic wasting disease herd certification program and interstate movement of captive
deer and elk. Federal Register, 66:247

U.S. Department of the Interior, Fish and Wildlife Service, and U.S. Department of Commerce,
U.S. Census Bureau. (2003). 2001 national survey of fishing, hunting, and wildlife-associated
recreation.

77

Vaske, Jerry J. et al. (2004). Chronic wasting disease in Wisconsin: hunter behavior, perceived
risk, and agency trust. Human Dimensions of Wildlife. 9(3), 211-231.

Watson,D. (1998). Tracking elk prices. North American Elk Breeders Association.

Will, R.G., Ironside, J.W., Zeidler, M. Cousens, S.N., Estiberiro, K., Alperovitch, A., et al.
(1996). A new variant of Creutzfeldt- Jakob disease in the UK. Lancet. (347), 921-925.

Williams, E.S., M.W. Miller, T.J. Kreeger, R.H. Kahn, and E.T. Thome. 2002. Chronic wasting
disease of deer and elk: a review with recommendations for management. J. Wildl. Manag.
66(3), 551-563

Williams, E.S., M.W. Miller, E.T. Thorne. 2002. Chronic wasting disease: implications and
challenges for wildlife managers. Transactions of the North American Wildlife and Natural
Resources Conference.

Wisconsin Department of Natural Resources. 2002. An analysis of risks associated with the
disposal of deer from Wisconsin in municipal solid waste landfills.

Wood, Alan K., R.J. Mackie and K.L. Hamlin. (1989). Ecology of Sympatric Populations of
Mule Deer and White-Tailed Deer in a Prairie Environment. Montana Department of Fish,
Wildlife & Parks.

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APPENDIX 1

PUBLIC INFORMATION PLAN

CHRONIC WASTING DISEASE

IN MONTANA

79

Public Information Plan

CHRONIC WASTING DISEASE IN MONTANA

While chronic wasting disease has not yet been detected among Montana's wild, free-ranging
population of deer or elk, we may not get to enjoy that distinction much longer. Infected herds of
free-ranging cervids border Montana (South Dakota, Wyoming, Saskatchewan), and it is reasonable
to expect that the disease will eventually enter the state. It is even possible that a Montana deer or elk
has already been infected but not yet detected.

Following the end of the 2004 big game season, Fish, Wildlife & Parks had tested over 7000
samples taken from deer and elk harvested in Montana for exposure to CWD. None of those
samples had tested positive for the disease. Sample collections in designated "high risk areas" for
possible CWD cases have been such that there is a 95% chance that CWD would be detected if it
were at a 1% incidence in the deer population.

In public scoping sessions held in conjunction with 2003 big-game tentative regulation meetings,
and in 2004 prior to initiation of a draft "CWD Management Plan" Montana's sportsmen and
sportswomen indicated that while they don't have many specific questions or concerns related to
CWD at this time, they expect FWP to be the lead agency in managing any infection among wildlife
in the state.

Considering the department's mission as steward of Montana's wildlife resources, it's appropriate
that FWP take the lead in providing public information about the disease and its implications, and
about any specific infection events. The details and tenor of the department's outreach will ensure
that reasoned judgment guides public discourse of this issue.

Equally important is that the department work with other agencies, especially Public Health and
Human Services and Livestock, to provide consistent, clear and accurate information regarding
possible risks of transmission to humans and other animals.

This Public Information Draft Plan is intended to prepare the department for the eventual arrival of
CWD, and will serve to identify key audiences and refine outreach activities.

THE PROBLEM

A positive test will generate enormous interest, from national and statewide media, from citizens
concerned about public health risks, from hunters and conservation groups concerned about impacts
to wildlife populations and hunting opportunities, and from interest groups affected by specific
management actions. Those interest groups may include meat processors and taxidermists who may
be economically affected, ranchers who may fear possible transmission to livestock, and solid waste
municipal landfills that may be responsible for proper disposal of contaminated materials.

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PURPOSE OF THIS PLAN

This plan details how FWP will develop and deliver public information, the type of message
appropriate for various scenarios, and the key audiences and potential affected interests who need to
be targeted. The goal of the plan is to gain the public's trust of, informed consent for, and potential
participation in various management actions, both immediate and long-term, related to CWD. Any
information will aim to minimize fear, overreaction and uninformed reaction and to be consistent
within FWP and other agencies.

OVERVIEW OF THE ISSUES AND PROBLEMS

Chronic wasting disease is an always-fatal, contagious disease affecting elk, white-tailed deer and
mule deer. The disease is a type of transmissible spongiform encephalopathy (TSE) that affects the
nervous system of these cervids. Some states have attempted to eradicate the disease once it is
discovered while other states where the disease has been present for years are trying only to manage
the disease by preventing an increase in its prevalence and preventing the spread to new areas. State
agencies, in most cases, have redirected priorities and resources to manage wildlife in the context of
the disease.

CWD tends to be a slowly progressing disease in an individual animal. In the initial phases of a
CWD outbreak in a defined population, the disease does not seem to rapidly decimate herd numbers.
More time and research will be needed, however, to determine long-term impacts on wildlife
populations. At this time, computerized models have indicated that long-term effects could
significantly reduce population numbers.

While there is no evidence suggesting that CWD can be transmitted to humans or livestock, the
public has repeatedly demonstrated that they fear transmission and will change behavior to minimize
that perceived risk. In some cases, meat from harvested animals has been discarded, creating a
sanitation and enforcement problem. In other cases, hunters have simply declined to hunt, an action
that has created revenue declines in some state wildlife agencies and has made management of the
disease more difficult. Most states dealing with the disease provide testing services - sometimes
free, sometimes expedited - to hunters. Although tests provide information on the prevalence of
CWD in given populations, they are not intended as an indication of the safely of consuming the
harvested meat.

In Montana, the key issues regarding CWD are its short-term and long-term impact on wildlife
populations, including reductions in range and densities; the impact on public health in terms of
possible transmission to humans; and the reduction in hunting as a form of recreation and wildlife
population control, with impacts to the state's economy. FWP should also be prepared for mistrust
of and resistance to management activities

Equally important as the known affects of CWD are the perceived impacts of the disease. The
department can defuse some expected reaction by researching and discussing other states'
experiences with the disease and by providing factual, consistent information.

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Specific behaviors the department can expect in the context of a CWD infection are:

• High volume of information requests, from media and citizens, of department personnel,
license agents, Hunter Education instructors, meat processors and taxidermists, guides and
outfitters, land-management agencies.

• Reduction in license sales.

• Administrative redirection of staff priorities.

• Criticism that FWP did not do enough to prevent infection and/or will not do enough to
contain infection.

• Criticism that FWP is being too aggressive in its reaction to CWD.

• Scrutiny and criticism from the public regarding specific management actions, possible legal
action (judicial injunction, etc.) to halt action.

• Geographical shift in hunting pressure away from infected area, with impacts on local
economies, license sales, Block Management cooperators.

• Increased demand for either free or expedited testing, both statewide and in the affected
region.

• Controversy or confusion over the various testing methods concerning their specificity,
sensitivity, and their intended purpose (i.e. not as a meat inspection test).

• Increased incidence of waste of game violations.

• Requirements for increased enforcement activity in an affected area.

• Possible accusations that human illness or death is attributable to CWD and, by extension,
the department.

• Possible accusations that CWD is FWP's fault.

• Loss of business for meat processors and taxidermists.

• Landowner distrust of agency, could close off sects of land to hunting, serving as possible
refuge for disease.

• Concern over appropriate disposal of deer and elk carcasses or carcass parts.

• Concern over the movement of harvested carcasses and carcass parts out of Montana or into
Montana from other states.

• Concern over potential spread to alternative livestock facilities.

INTERNAL ACTIVITIES

• The FWP Wildlife Laboratory and Wildlife Division will review and solicit comments from
headquarters management team and regional supervisors on this information plan and the
department's "Chronic Wasting Disease Management Plan for Free Ranging Wildlife in
Montana" document. The goal will be to gain informed consent of managers charged with
implementing specific management actions outlined in plan.

• FWP will (through Conservation and Education and other divisions) coordinate CWD-related
public information with other state departments, including Public Health and Human
Services and Livestock.

• The FWP Commission will be briefed on CWD plans.

• ConEd, with input from other divisions, will prepare generic news releases and
accompanying fact sheets in advance of test results.

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INTERNAL PROTOCOL AND ACTIVITY CHRONOLOGY

• Just prior to and during annual big game seasons, FWP will coordinate with other agencies
(esp. Health and Livestock) on public-information planning.

• Just prior to and during annual big game seasons, FWP will develop draft news releases and
fact sheets in advance of test results.

• If a positive CWD test is obtained from a deer or elk that is harvested or dies in Montana,
notification to appropriate personnel and agencies will take place according to the following
protocol:

1. The laboratory receiving the positive test result (FWP Wildlife Disease Laboratory) will
notify the FWP Directors Office, the FWP Wildlife Division Administrator, and the
Regional Supervisor in the region affected.

2. An Enforcement representative will contact the hunter (if appropriate) to determine the
exact kill location and to determine the status of the harvested animal.

3. An Enforcement representative will contact the landowner or land manager where the
animal was harvested.

4. FWP designee will contact the Montana State Veterinarian, State Epidemiologist, and
Regional USDA veterinarian and inform them of the positive animal, including details of
where and when the animal was harvested.

5. The CWD Management Team, consisting of members of FWP staff from the affected
region(s), FWP Directors Office, Wildlife Division, Enforcement Division, Con/Ed
Division, and from the Department of Livestock, Department of Public Health and
Human Services, the Governor's office, and any Tribal, Federal, or State land agency
with jurisdiction over any lands within 20 miles of the affected area will be alerted and
convened.

6. FWP designee will alert department employees and partner agency contacts including
USFWS, NPS, USFS, BLM, Tribes; news release, fact sheet, and speaking points will be
included in the notification.

7. FWP designee will prepare and distribute news release materials and accompanying fact
sheet to statewide and local media.

8. A public meeting will be scheduled in the affected region to provide additional
information and to answer questions from the public. Potential management actions will
be presented.

9. Informational letters will be sent to non-resident hunters who request deer and elk license
applications.

10. FWP website will be updated to provide additional and current CWD information
including test results and map of test result locations from around Montana.

CONTENTS OF PUBLIC INFORMATION MESSAGE

*The details in this section assume management of information following a positive test*

News release and accompanying fact sheet for statewide distribution should include the following
points:

• Specific species, age, sex, geographic area, date and prior level of testing in area
that infected animal was harvested

• Brief description of disease, its history, and consequences of the disease as seen in
other states

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• Herd population numbers and susceptible species in the area.

• Specific management actions recommended in FWP's Management Plan, with
rationale for action stressing need to determine the prevalence of disease before
management plans are implemented.

• Accompanying the above, a statement that management actions aren't guaranteed
to "eradicate" the disease, but that inaction is not a valid alternative.

• Announcement of public meeting in affected area and in all FWP administrative
regions to discuss incident and department responses

• Statement that FWP has been looking for disease, with specific attention to "high-
risk areas" and is not surprised at its arrival. Include maps showing distribution of
samples collected since 1998.

• Nationwide distribution of CWD and an overview of management responses and
outcomes in other states.

• Review of risk of transmission to humans; consumption advisories ("Hunters
should never eat meat from an animal that appears sick, and even in a healthy
animal, the nervous and lymphatic tissues should not be consumed"). Refer to
language detailed in FWP's Chronic Wasting Disease pamphlet.

• Assurance that FWP has contacted the hunter who submitted the positive sample
and has waived requirement that meat be consumed. Also assurance that
landowners within a 5-mile radius of where animal was harvested have also been
contacted.

• Assurance that FWP is contacting landowners and land-management agencies in
affected area, specifically asking trespass permission, where appropriate, in order
to conduct management activities.

• Requirement that hunters in the affected area in subsequent seasons will need to
submit heads of deer and elk for testing. Results of tests will be expedited and
made available to the participating hunters.

• Requirements for disposal of carcass wastes and/or contaminated carcasses,
especially from affected areas.

• Announcement of updated FWP web site devoted to CWD issues in general and
infection incident in particular

• Details on contacting FWP and Health and Human Services (county health
departments, regional and statewide phone numbers), plus respected sources of
CWD information (web sites, etc.), including Centers for Disease Control, World
Health Organization, CWD Alliance, etc.

• Q&A format addressing basic questions of disease and its implications.

MESSAGE DELIVERY MECHANISM TO MEDIA

Immediate outreach activities:

• Phone calls to first-tier media outlets (AP contact, primary
Conservation/Education division media contacts, et al).

• Convene news conference in Helena at FWP headquarters. Hagener, Aune,
Aasheim, Childress, Palmer, Feldner in attendance.

• Statewide news release package (infection incident plus Q&A fact sheet)
distribution to statewide media including newspapers, television, and radio.

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• Regional news release package in affected region (ensure that Regional
Information Officers have updated media distribution lists for their regions).

• Updated information on FWP web site

• Speaking points provided to state and regional personnel involved with media
outreach.

Secondary outreach activities:

• Letter on status of CWD in Montana to accompany non-resident deer and elk
license applications.

• Letter to license agents, Hunter Ed instructors, meat processors, taxidermists,
county health departments, livestock associations.

• Letters to landowners in affected area(s). Important to keep them directly
informed.

KEY AUDIENCES AND POTENTIALLY AFFECTED INTERESTS

• FWP Commission

• FWP staff

• State agencies - Dept. of Livestock, State Epidemiologist, State Veterinarian, Dept. of
Health, DNRC, Board of Outfitters, Tourism

• Federal agencies - U.S. Fish & Wildlife Service, BLM, National Park Service, Forest
Service, USD A/APHIS

• Tribal governments

• Local jurisdictions - county commissions, county health departments, conservation districts,
grazing associations

• Wildlife agencies in neighboring jurisdictions

• Stockgrowers, alternative livestock associations and landowner organizations

• Media - local, statewide newspapers, radio, TV, websites, national magazines, western
media (CO, WY, SD, etc.)

• Legislators

• License agents

• Montana and non-resident hunters

• Commercial meat processors/taxidermists

• Outfitters/MOGA

• Statewide conservation groups and local sportsmen's clubs

• Hunter Ed and Bowhunter Ed instructors

• Universities

• Landfills, waste facilities

MISC. CONSIDERATIONS

• Department will announce annual surveillance results even if all tests are negative. This
action will further educate public about sample collection and testing results following each
hunting season.

• Department should also inform public that testing is ongoing, via road kill collection and
targeted surveillance, and that results may be returned at any time of the year.

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ACTION ALERT PHONE TREE

• Neil Anderson (Wildlife Disease Laboratory 994-6358) or Dr. Tom Linfield (Montana State
Veterinarian 444-0782)) learn of positive test result(s)

• Anderson or Linfield call FWP Director's Office (444-3186) and Wildlife Division (444-
2612)

• Wildlife or Director calls Conservation/Education Admin. Ron Aasheim (444-4038),
supervisor of affected region, CWD management team

• Aasheim calls Tom Palmer (444-3051) and Andrew McKean (228-3723) who prepare
news release

• Aasheim contacts departments of Livestock's Karen Cooper (444-9431), state
epidemiologist Todd Damrow (444-3986)

• Enforcement Division contacts hunter and landowner, affected jurisdictions

• Palmer distributes information via email to FWP All

• Aasheim and Palmer contact first-tier media

• Palmer distributes news release and fact sheet to statewide media

MANAGEMENT ACTIONS

Management actions taken in reaction to the diagnosis of CWD in a Montana deer or elk will vary in
their aggressive nature depending on the CWD Management Plan selected as being most capable of
limiting or eliminating CWD. In all cases, additional sample collections will be required to
determine disease prevalence. Carcass transport issues may restrict movement of carcasses or
carcass parts out of the management area and special hunts may be initiated to supply needed
samples or to effect population densities in management areas. All of these actions will require the
distribution of additional public information. Press releases, television and radio coverage, local
public meetings, and on site presence in management areas by FWP personnel to collect samples and
distribute information may be required. Concentrated informational efforts targeting landowners,
land agencies and/or Tribes, sportsmen, waste disposal facilities, involved state agencies, and the
general public will be initiated by the CWD Management Team prior to beginning management
actions.

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APPENDIX 2

MULE DEER POPULATION ECOLOGY

AND
CHRONIC WASTING DISEASE STUDY

SOUTHEASTERN MONTANA

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DRAFT Mule Deer Population Ecology and Chronic Wasting Disease Study
Southeast Montana

The southeastern corner of Montana represents a probable entry point for Chronic Wasting Disease
(CWD). CWD is a neurodegenerative disease characterized by changes in behavior, progressive
weight loss, and ultimately death (Williams and Young, 1980, 1982, 1992, and Spraker et al. 1997).
The disease has not been detected in Montana among 4,643 samples collected from free-ranging
populations of deer or elk during organized statewide surveillance conducted 1998-2003 (Anderson
and Aune 2004). Prevalence or susceptibility appears to be higher in mule deer and white-tailed
deer compared to elk in endemic areas of Colorado and Wyoming (Miller et al. 2000). In the Black
Hills of South Dakota, mule deer, white-tailed deer, and elk from free-ranging populations have
tested positive for CWD, some as close as 70 miles from the southeast corner of Montana. Free-
ranging mule deer near Moorcroft, Wyoming, have tested positive for CWD approximately 50 miles
south of where the Little Powder River enters Montana.

Loss of cervid populations, reduced hunting opportunities, and perceived threats to human health
have elevated public concern over entry of the disease into Montana. In contrast to neighboring
states, Montana has an opportunity to prepare for the probable occurrence and detection of CWD.
Mule deer represent the most likely species to transmit the disease across our borders because of
their wide distribution and seemingly high degree of susceptibility to the disease. Mule deer habitats
supporting relatively high densities in southeast Montana are continuous with areas of South Dakota
and Wyoming that have tested positive for CWD. Montana FWP has studied population ecology of
mule deer in a number of important environments (Mackie et al 1998, Pac et al 1991, Hamlin and
Mackie 1989, Wood et al 1989) although such data are lacking in the extreme southeast corner of the
state. A scientifically valuable opportunity exists to study population demography before the disease
is detected and, quite probably, after it's occurrence and expansion. The ultimate impact of
mortality caused by CWD on size and trend of wild populations has not been determined.

We have initiated efforts to study mule deer populations in two different environments in Southeast
Montana to describe population size, composition, density distribution, movement patterns,
emigration rates, and habitat use along the Montana border adjacent to Wyoming and South Dakota.
These data are fundamental to designing an ecologically effective CWD response plan for southeast
Montana. The Boxelder Creek study area represents the sagebrush/grassland prairie that
predominates to the east and south of Broadus, Montana. The proposed Devil's Backbone study
area represents the ponderosa pine upland habitat predominating to the south and west of Broadus.
Approximately 25 landowners have been contacted and have given permission to FWP personnel to
conduct research on their properties.

The general study objectives described below apply to both study areas with the exception of
Phase I l.a. which, will be directed only toward the Boxelder study area.

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PHASE I OBJECTIVES-

1. Describe and monitor the demographics of a mule deer population in a sagebrush/grassland
environment prior to documented exposure to CWD.

a. Estimate trends in population size and composition during a 4-year period.

b. Determine causes and rates of mortality of adult females and males during a 4-year
period.

2. Determine the seasonal movement patterns and density distribution of adult females and males
with emphasis on interstate movements along the South Dakota and Wyoming border.

3. Measure use vs. availability of large-scale habitat types at the landscape level for the VHF radio-
collared sample of adult females and males.

4. Intensify CWD surveillance in southeast Montana with emphasis on harvest of mule deer, white-
tailed deer, and elk.

5. Develop a CWD response plan for southeast Montana incorporating data on population ecology
of mule deer in the sagebrush/grassland prairies and ponderosa pine habitats.

PHASE II OBJECTIVES

1. Determine the seasonal movement patterns and emigration of juvenile female and male mule
deer.

2. Measure fine-scale habitat use vs. availability on individual home ranges of adult females, adult
bucks, and possibly juveniles.

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