Pennsylvania Game Commission Proposal to Ban Urine Scents for all Hunting- HOW TO SUBMIT COMMENTS IN OPPOSITION

Public Comments can be submitted via email: [email protected]

Background- The Pennsylvania Game Commission has introduced a 2nd generation of their CWD Response Plan, which unlike the first generation, proposes to ban the use of all scents and attractants in the entire state. We are encouraging hunters to contact the Commission and comment before May 7th to oppose this part of their plan.

Sample Email below:

Comments: Write a brief note opposing this specific part of the proposed regulation. You can use these points to guide your note

1. Using natural deer scents is a long tradition for Pennsylvania hunters, and there are urine-based products from responsible sources with carefully monitored deer herds that are tested to make sure they do not have CWD prions.
2. Natural urine attractants that are applied in less than 1-ounce quantities during hunting season are not a major congregation risk compared to the millions of gallons of urine deposited by wild deer. If anything, using these products adds additional scent locations to what occurs naturally and makes the hunt more successful, both of which aid in reducing congregation.
3. The same test used to confirm that urine could contain CWD prions in academic research is the test being used by manufacturers to ensure that their products do not have prions. The RT-QuIC test is reliable, has been utilized in dozens of peer reviewed research papers, and is commercially available. Tested products have a clearly identifiable logo on them.
4. The ATA Deer Protection Program is a very robust certification process, less than a dozen production facilities have qualified for its seal of approval. These facilities can supply the industry without disruption as they are supplying most of the material used by the major manufacturers today.
5. Other states have adopted regulations requiring the urine scents used in their states come from sources certified by the ATA Deer Protection Program, including Michigan, Tennessee, Mississippi, Montana, Alabama and Louisiana. Louisiana also requires RT-QuIC testing.
6. Regulations should protect the deer herd with the least possible disruption to hunters. A blanket prohibition of scent products appears to be intended to be “easy to enforce”, but in practice will do nothing to reduce risk of CWD spread.

Please include your name and address.

More information on PGC’s CWD Plan can be found at: https://www.pgc.pa.gov/Wildlife/Wildlife-RelatedDiseases/Documents/CWD%20Response%20Plan.pdf