Comment from Philip D Gordon, Tennessee Department of Agriculture

1. I do not think that establishing the acheivement of 2nd year status, at this late date, will have an economic impact other than penalizing those herds which have already acheived 6 year or "Certified" status in an equivalent state program. In my opinion, most herds not already enrolled in some state program cannot catch their animals to enroll them anyway--at least that is the case in Tennessee. 2. Please list all the animals in the genera Odocoileus, Cervus, and Alces or let us know a convenient source of such a "list". 3 55.24 (b) (2) (ii) appears to involve a lot of risk 4. Nowhere is there mention of the accredited veterinarian. What role, if any, will the accredited veterinarian have in conducting a. official herd inventories and b. testing of death losses 5. If the final rule preempts state rules, does it also preempt other state agency rules i.e. state wildlife agencies 6. Unclear on the 2nd form of ID--a simple numbered dangle tag without something identifying the premise or to make it unique is or is not acceptable 7. If captured from the wild are included in the definition of farmed or captive, then how can you not hold them to the same enrollment requirements you do the other farmed or captive----does not make any sense at all and extremely unclear/confusing especially as 81.3 (2) and (2) (b).treat them otherwise.