A proposal under consideration by the Pennsylvania Game Commission in the effort to combat chronic wasting disease could have a significant impact on hunters and the state’s deer farms.

The PGC is fine-tuning the latest draft of its new Chronic Wasting Disease Response Plan, and it could be approved before the Oct. 3 opener of the statewide archery season. The plan is used by the agency as a blueprint for managing CWD in deer and elk, and it outlines several actions that could be implemented to achieve those goals.

Among the actions being considered are a statewide ban on feeding deer, including the use of minerals or supplements; a statewide ban on the use or field possession of deer attractants, including natural urine and synthetics; increased hunting opportunities within CWD areas and the removal of deer antler-point restrictions within CWD areas.

While the impact to hunters is obvious, the move would also have drastic consequences for the captive cervid industry both in Pennsylvania and nationally. The industry supplies the natural deer urine that is used by hunters, and a ban on those products in Pennsylvania would take away a major market, according to Josh Newton, president of the Pennsylvania Deer Farmers Association. The game commission is considering a ban on deer urine because it’s believe the substance can carry CWD prions if collected from an infected deer. The agency also wants to lessen the likelihood of congregating deer — which is an avenue for transmission of CWD — attracted to scents such as urine.

Newton said there are 750 deer farms in Pennsylvania, and deer urine collection is one of several commerce opportunities for those operations, in addition to raising animals for hunting and breeding stock.

Banning the use of deer urine, Newton said, disrupts the supply chain for many cervid farms that raise animals for other purposes but market the urine as a byproduct of the business.

“Raising animals is hard, and the ability to have multiple means to make money is important,” said Newton, who is also the operations manager of Cervid Solutions, LLC in Williamsport. “Banning deer in urine in one state has ramifications throughout the industry, and Pennsylvania is a big market.”

Newton said the use of natural deer urine by hunters is a proven tool to help aid the harvest of deer, particularly in areas where the Game Commission would like to see numbers reduced. That includes Disease Management Areas — those parts of the state where CWD has been found and the PGC is trying to keep deer numbers down to prevent the spread of the disease.

Besides the benefit of deer urine for hunting, Newton questioned if the risk it poses is really that significant.

He said the concentration of CWD prions in the urine, saliva and feces of a positive animal is very low, while the higher concentrations are found in the lymph nodes, spinal cord and brain tissue.

“A paperclip-size of brain matter from a positive animal is equal to 30,000 gallons of urine when it comes to prion concentration,” Newton said. “Urine is way low on the infectious sheet.”

As far as congregating deer, Newton also took exception to that claim.

“A hunter with a 1-ounce bottle of deer urine hanging from a tree, I don’t see it having a big impact,” he said.

“We have to be reasonable. Nothing is zero risk and CWD is here, so we need to be smart about it and look for a solution. As a farm cervid industry, that’s what we want.”

At most collection facilities, deer are closely monitored and tested to ensure they aren’t CWD-positive, Newton said. In fact, the same test used to confirm the presence of CWD prions for research purposes is also being used by deer urine manufacturers to keep their products safe, he added. In addition, the Archery Trade Association has an intense CWD-free certification program and less than a dozen facilities have qualified for its seal of approval, Newton said, and those operations provide most of the deer urine used by manufacturers across the country.

Testing deer for CWD — which can only be done on a deceased animal — and implementing more regulations isn’t the answer to solving the CWD issue in the state, Newton said. Instead, he believes the focus should be on genetics. Current research is shedding light on why some animals aren’t getting CWD, Newton said, and is could lead to deer farmers being able to breed away from the risk of the disease at some point. The approach is similar to what happened with sheep farmers that used genetics to reduce the risk of scrapies in their flocks, he said.

Until that happens, however, the cervid industry will continue to brace for more regulations that could bring more financial burden. According to Newton, the cervid industry in Pennsylvania has already decreased by 35% due to regulations enacted in response to CWD.

“Our intention isn’t to spread disease,” he said. “But we need to turn what the science is telling us into a regulatory document that’s sensible and allows people to operate their business without burden.”

Public comments on the plan are being accepted until May 7. After that, PGC staff will make final adjustments to the draft plan and then the board of commissioners will hold a special meeting to discuss the next step, which means either adopting the plan as presented or approving certain items, according to agency spokesman Travis Lau.

While there isn’t a date set for the special meeting, Lau said it could occur in May. Depending on how things progress and how much of the plan is adopted by the board, it’s possible that archery hunters statewide will be prohibited from using natural deer urine or synthetic versions as soon as the 2020 season.

The implementation of the plan, including the prohibition on the use of deer attractants, could come even sooner if it’s done via an executive order as opposed to the regulatory process. The latter step, according to Lau, would require votes at two board meetings and that could make the prohibition official after the archery season is already underway.

“It’s possible,” Lau said when asked if a deer urine ban could be in place for the 2020 archery season. “Staff is recommending that we ban all deer attractant statewide.

“It’s not a new idea. It’s been discussed previously.”

While synthetic deer lure contains none of the prions believed responsible for CWD, Lau said those products are being considered in order to minimize the congregating of deer.