09/22/2026
The Agency-Funded Hit Piece on the Captive Industry
Part 1: Who Decided What Was “High Risk”?
Here is what every deer hunter and deer breeder needs to understand about Cornell’s CWD Hazard Model.
The model tells wildlife agencies where to look for CWD and what areas to treat as high risk.
So who decided what was high risk?
The agencies helped decide.
Schuler’s own paper says:
“In the absence of empirical risk data, we solicited perceptions from subject matter experts…”
It gets even clearer. Cornell convened experts from wildlife agencies and academia to identify potential sources of CWD introduction. Then, with input from regulatory agencies, surveys were tailored for each state and given to agency biologists, administrators and law enforcement to assess their “perceived risks” and calculate risk scores.
I’m really not sure what empirical data they were lacking. Case after case of CWD detection had already been documented for decades.
But instead of deriving those hazard weights from that historical record, Cornell says the model can use current expert opinions “in lieu of empirical data.”
Think about what that means.
Agency personnel helped identify what they wanted profiled. Agency personnel supplied their perceptions of how risky those things were. Those perceptions became numerical weights. Those weights helped determine where the model told those same agencies to concentrate CWD surveillance.
And these opinions weren’t being collected in a philosophical vacuum.
Wildlife agencies and major professional wildlife organizations have repeatedly taken policy positions opposing expansion of high-fence and captive-cervid operations.
Schuler’s own earlier work had already demonstrated the divide. When different groups were asked to rank CWD risks, wildlife-agency biologists and independent wildlife professionals placed substantially greater risk on captive cervids than captive-cervid owners, hunters and agricultural personnel did.
But remember what that study measured:
Perceptions.
It didn’t establish that the wildlife agencies’ perception was empirically correct. Yet those same types of professional judgments ultimately became inputs used to assign risk in a model telling agencies where to look for CWD.
Then the money started flowing.
And we’re not talking about a few thousand dollars.
Cornell’s own records document more than $1.4 MILLION in CWD surveillance optimization, modeling, infrastructure and state risk-assessment projects associated with this broader effort.
The larger awards alone include projects of approximately $224,326, $310,285, $274,723, $246,395 and $277,662 for various components of CWD surveillance optimization, infrastructure, modeling and expansion.
Then there were individual state projects.
Tennessee — $28,200.
Georgia — $20,296.
South Carolina — $20,296.
Virginia — $20,296.
Florida — $25,000.
Alabama — $43,896.
And those aren’t even all of the states involved.
So strip away all the technical language and follow the process.
Wildlife agencies helped identify the hazards.
Wildlife-agency personnel supplied their perceptions of the risks.
Cornell converted those perceptions into numerical risk weights.
Those weights went into a model designed to tell those same agencies where the risk was and where to look hardest for CWD.
Then government agencies and government-funded programs poured more than $1.4 million into the broader surveillance and modeling effort and state-specific work.
That is why the methodology matters.
A number generated by a model looks scientific. A colored risk map looks scientific. But the number is only as objective as the assumptions and information that went into producing it.
If the underlying risk weight began as an agency professional’s perception, converting that perception into a numerical value doesn’t magically turn it into empirical evidence.
And Schuler’s paper tells us plainly that they were working “in the absence of empirical risk data.”
Again, I have a hard time accepting that there was no information available to examine.
CWD had been documented for decades.
There were captive detections. Wild detections. States with captive industries. States without them. Areas where CWD appeared around facilities. Areas where it didn’t. Captive herds that tested positive. Surrounding wild populations that remained negative. Major free-ranging outbreaks for which no captive source was established.
There was a national history to examine.
Instead, agency perceptions were used to help assign the risk.
Then agencies paid for the work.
Schuler went to agency personnel for their opinions, those opinions helped determine what the model would profile as risk, and then agencies paid Cornell for the results.
That’s not the same thing as starting with decades of national CWD data and letting the data tell you what the greatest risk actually is.
And this is only Part 1.
Part 2: We’re going to compare those agency perceptions with a completely different expert-elicitation study—one that assembled CWD and prion specialists, tested their expertise and performance-weighted their answers.
Wait until you see what they ranked slightly higher than direct deer-to-deer transmission.
Part 3: Then we’re bringing it home to Alabama: who commissioned Alabama’s Cornell assessment, how much Alabama paid, where some of that money came from, the people running the program—and what happened when the same agency leadership later went after HB509.
