TPWD Proposed Rule Changes related to CWD and Suspension of TTT Permit

TPWD Proposed Rule Changes related to CWD and Suspension of TTT Permit

TPWD Proposed Rule Changes related to CWD and Suspension of TTT Permit

October 26, 2021 by

Your help is needed NOW!

Re: TPWD Proposed Rule Changes related to CWD and Suspension of TTT Permit

As a part of rule changes related primarily to Chronic Wasting Disease (CWD) and Deer Breeders, TPWD is proposing to suspend the TTT Permit indefinitely. This means there would be no more TTT Permit at all, leaving properties with excess deer to either shoot or TTP (Trap, Transport, Process) their deer and leaving those with properties with few or no deer with no other alternative except to purchase captive-held breeder deer.  TTP has very high standards to qualify so the average property may not qualify, further forcing  landowners to shoot all surplus deer. TPWD has made this decision with no input from anyone affected by this suspension apart from the brief public testimony allowed in August 2021 (photo shows Macy’s powerful testimony during that hearing). The proposed rules were on the agenda for the September 15, 2021 TPWD Commission Special Work Session, but testimony was by invitation only, with no stakeholders invited to speak about the TTT Permit. The rules were again discussed at a Joint Hearing of Senate Agriculture & Livestock and House Culture, Recreation, & Tourism Committees on September 29, 2019, again, by invitation only, and again, with no representation from any TTT Permit stakeholder. 

Following the TPWD Commission’s Special Work Session, the proposed rules were published to the Texas Register and public commenting was opened. The Preamble of an entry in the Texas Register gives background and explanations for proposed rules. The preamble to these proposed rule changes barely mentions the TTT Permit. In the required segment about how rule changes will impact local economies and communities, the impact of suspending TTT is not mentioned at all, although ample evidence of severe economic impact has been provided to Mitch Lockwood and the TPWD Commissioners. Finally, an additional major change to the TTT Permit, never before mentioned, has been slipped into the Texas Register—that a property that has EVER released breeder deer in the past will be banned as a TTT trap site. The current rule states that a ranch is required to wait for five years after releasing breeder deer to be eligible to trap TTT deer. This designation of having released breeder deer in the past stays with the property forever, even if it changes ownership.

Links to all the background information are listed below. At a minimum, please view the attached PDF of the Texas Register October 8, 2021 edition where we have highlighted and annotated the key portions. The TPWD Proposed Rules begin on page 50 of the attachment. Please let us know if you have any questions or if we can help you find more information. But most importantly---SUBMIT A COMMENT TO TPWD!! And pass this message and the attachment along to others who have a stake or interest in the TTT Permit.

The deadline for commenting on the TTT rule change is November 3, 2021 at 5:00 pm. 

Remember—The rules are made by those who show up. This is the time for you to show up by commenting on these proposed rules!

HERE IS THE LINK TO COMMENT ON THE PROPOSED REGULATIONS:

https://tpwd.texas.gov/business/feedback/public_comment/proposals/202111_cwd_manage.phtml

You will fill out the top portion with your name, county, and hunting license status, then scroll all the way to the bottom of the page and there will be 4 bubbles to chose from, select "Disagree Completely" and then you can write any additional comments in the text box below that. They have put a tiny text box there but don’t hold back—you can type up to 5,000 characters, about two pages worth of text. It is safest to type your comment in your notes or word processing app then copy and paste your comment to the box. This will work, I have tried it. 

The deadline for commenting on the TTT rule change is November 3, 2021 at 5:00 pm.

Proposed Rules may be found here:

PDF

https://www.sos.texas.gov/texreg/pdf/backview/1001/1001prop.pdf

Click here for PDF of October 1, 2021 Texas Register Annotated by SCO

HTML

https://www.sos.state.tx.us/texreg/archive/October12021/Proposed%20Rules/31.NATURAL%20RESOURCES%20AND%20CONSERVATION.html#60

You can read the agenda of the Commission September 15 Special Work Session here and download an MP3 of the entire meeting if you’d like to listen to it. 

https://tpwd.texas.gov/business/feedback/meetings/2022/0915/agenda/

You may watch the Joint Hearing of Senate Agriculture & Livestock and House Culture, Recreation, & Tourism Committees on September 29 here:

https://house.texas.gov/video-audio/committee-broadcasts/ 

If you would like to hear public testimony that was given to the TPWD Commission on August 25, you may download an audio file here: (Be aware that testimony covered a wide variety of topics besides deer-related topics)

https://tpwd.texas.gov/business/feedback/meetings/2021/0826/agenda/

From the Proposed Rules Preamble: “Comments on the proposed rule may be submitted to Mitch Lockwood, Texas Parks and Wildlife Department, 4200 Smith School Road, Austin, Texas 78744; (830) 792-9677; email: mitch.lockwood@tpwd.texas.gov or via the department website at https://tpwd.texas.gov/business/feedback/meetings. “ 

 

The deadline for commenting on the TTT rule change is November 3, 2021 at 5:00 pm.

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