ALERT: DEADLINE Public Comment Amphibian Listing!

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default ALERT: DEADLINE Public Comment Amphibian Listing!

Post by LRE on December 11th 2010, 1:42 pm

~Email Received From USARK on December 11th, 2010~

DEADLINE Thursday December 16, 2010

The deadline for the USFWS public comment period regarding the the listing of ALL Amphibians on the Injurious Wildlife list of the Lacey Act is NEXT Thursday at 11:59 PM. EVERYONE NEEDS TO COMMENT!!

The following are guidelines from USARK to the Reptile Nation on “How To” make a highly effective public comment on the USFWS Notice of Inquiry (NOI) entitled, Injurious Wildlife Species; Review of Information Concerning a Petition To List All Live Amphibians in Trade as Injurious Unless Free of Batrachochytrium dendrobatidis. It is extremely important that you make public comment! Your comments should be thoughtful and pertinent. Please DO NOT plead for your animals, complain about fairness, or give your political philosophy regarding regulation. If you have put a lot of thought and effort into your comments please email to USARK so we can see them. Read below for the best suggestions of “How To” make public comment.

***If you know any government agency scientists, university academics, veterinarians or zoo professionals please request they make public comment by the deadline!!!



USARK Recommendations for Making Public Comment:

• It is highly suggested that your comments be original and written by you. There seems to be confusion about ‘How To’ and ‘Where To’ make comment. The following is ‘step by step’ on how to make a fast and easy comment:
1. Go to the government portal.
2. Fill in the fields for Name, Country, City and Postal Code. Ignore the rest of the fields.
3. Copy the Sample Letter below. Modify it with your own comments (HIGHLY SUGGESTED). Save it into a Word, Works, Note Pad or PDF file. Click the Browse button on the Attach File field and download your file. (you can not cut & paste more than 2000 characters into govt portal)
4. If you are a business copy Sample Letter onto company letterhead and save as a Word, Works, Note Pad or PDF file. Click the Browse button on the Attach File field and download your file. (if you are NOT a business skip step 4)
5. Click Submit button. You're Done! (If you are successful you will get a confirmation number)

***If your comment is more than 2000 characters save it to a Word file or PDF and use the 'Attach File' field at the government portal to upload your document.

-------- CLICK HERE TO GO TO GOVERNMENT PORTAL -------- http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480bb062b


SAMPLE LETTER: (Copy Into Word file or PDF- Please edit & make your own- submit through link above)

U.S. Fish and Wildlife Service
Division of Policy and Directives Management
Attn: Docket No. FWS-R9-FHC-2009-0093
4401 N. Fairfax Drive, Suite 222
Arlington, VA 22203

RE: Docket No. FWS-R9-FHC-2009-0093

Dear Fish & Wildlife Service,

As a supporter of the United States Association of Reptile Keepers (USARK) and someone who is concerned about the environment, I am writing today to OPPOSE the Petition To List All Live Amphibians in Trade as Injurious Unless Free of Batrachochytrium dendrobatidis as submitted by the Defenders of Wildlife and posted to the Federal Register as a Notice of Inquiry (Federal Register /Vol. 75, No. 180 / September 17, 2010).

I am very concerned about the economic impact of listing all amphibians on the Injurious Wildlife list of the Lacey Act; and what it would mean to my business and ability to support my family. The precautionary principle recommended by the Defenders of Wildlife endorses a guilty until proven innocent approach that reveals a more ideological motivation. The Lacey Act was not designed to be used as is being proposed. Never was it intended to include native animals or micro organisms that could potentially be hitch hikers. Never have so many animals, so widely held and traded by the American public been proposed for listing. Defenders of Wildlife cannot possibly be unaware of these facts, nor the cost prohibitive testing that would have to be done to comply with such a listing. The Lacey Act is an inflexible, ineffective tool which will do little to address problems in wild populations, while making millions of Americans potential felons, and devastating thousands of small businesses.

USARK has developed Best Management Practices in an effort to secure animals in captivity and mitigate risk of contributing to problems in wild populations. Secure containment and environmental protocols ensure minimal risk from the Herp Industry and pet owners. Small business’ like mine, while having nothing to do with the spread of chytrid fungus in the wild, take more precautionary measures and would potentially be more impacted by a listing than any other stake holder group. The inability of Lacey Act to focus on actual problems and provide pragmatic remedy reinforces that it is an inappropriate tool to address this issue. Our animals are valuable and securely contained. They will never be exposed to wild populations.

I don’t believe that FWS has the resources or ability to enforce an unprecedented listing with such far reaching implications. It seems to me that FWS already struggles to administer the duties with which it has already been tasked. I understand the mandates under which FWS must respond to the petition fielded by Defenders of Wildlife, but they are attempting to redefine Lacey Act into a tool to change the way America looks at and treats animals. It is not the job of our federal government to satisfy the ideological goals of a powerful special interest group. A listing of this nature would negatively impact my family and business.

Sincerely,

_________________
Thank You,
David
Lexington Reptile &
Exotic Pet Expo
www.lexingtonreptileexpo.com

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default Re: ALERT: DEADLINE Public Comment Amphibian Listing!

Post by LRE on December 11th 2010, 1:53 pm

Please do your part in protecting our animals, our rights & our hobby! Send in your letter today before it is too late!

_________________
Thank You,
David
Lexington Reptile &
Exotic Pet Expo
www.lexingtonreptileexpo.com

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default Re: ALERT: DEADLINE Public Comment Amphibian Listing!

Post by david.cravens on December 14th 2010, 10:02 am

Remember its not FWS targeting our hobby on this one, instead their hand has been forced by defenders of wildlife to act upon this issue. If they had refused to listen defenders of wildlife would have taken them to court and forced the issue to be resolved there.

I don't believe in blanket statements where you copy and paste someone else's response and simply sign it, yea that works for petitions but in this case a letter is needed. Here are some drafting points off of fauna, actually read the regulation before commenting please. I would do anything to stem the flow of chytrid and in some aspects I like the idea that transportation can only be done when cleared, however there are some issues that need to be addressed beforehand....

DRAFTING POINTS
State that you are responding to NOI question #14 from your personal perspective and that PIJAC will be responding to questions #1-13 on behalf of its members. [Note: If you have data and are confident in the technical accuracy of your responses to questions 1-13, we do encourage you to address those as well.]
• Research indicates that the chytrid fungus, Batrachochytrium dendrobatidis (Bd), is pathogenic to some, but not all, amphibian species. Maps produced by a team of researchers, including Federal agency scientists, indicate that it is already widespread in the United States. Furthermore, some scientists believe that it may be native to – or long established in – the eastern US.
• In response to the Defenders of Wildlife petition referenced in the NOI, the US Department of Agriculture (USDA) has determined that Bd is “non-actionable” because it is already widespread within the US. The Department of the Interior and USDA are partners under the National Aquatic Animal Heath Plan (NAAHP) and we question the ability of the USFWS to provide the administration, infrastructure, and budget necessary to unilaterally implement an injurious wildlife listing that is consistent with the NAAHP, as well as international guidance and law (e.g., OIE standards).

• We do not believe that it was the intent of the authors of the Lacey Act to list native wildlife as injurious. Nor do we believe that there is authority under the Lacey Act to list micro-organisms or vertebrate species that might carry micro-organisms as hitchhikers (whether or not those micro-organisms might/might not cause disease).
• Amphibians imported and transported for the pet trade are intended for life-long, secure containment. Escapes or deliberate releases in the natural environment are extremely rare given the volume of amphibians in trade. The greatest risk of Bd spread within the US is via “on-the-ground” pathways, e.g., fish stocking, fishing, boating, water transport (e.g., canals, irrigation).
• The pet industry is already well-aware of the risks posed by Bd and has led the way in taking proactive responsibility/measures for minimizing Bd spread via its pathway/practices (e.g., Bd-free ‘Phibs campaign and individual company programs for testing/treatment of Bd). Members of the pet industry care about their stock for both animal welfare and economic purposes. The pet industry is well-positioned to self-regulate the spread of Bd.
• It is not clear how the USFWS would implement a program of Bd treatment, testing, surveillance, reporting, and permitting. The USFWS must be consistent with international trade law and the OIE has not yet completed its guidance on amphibians and Bd. We strongly suspect that the USFWS will not have the capacity to implement the guidance that the OIE develops in a timely and economically-feasible manner.
• Treatment protocols for amphibians need to be carefully developed in accordance with animal welfare standards. If an amphibian has to be dosed when it crosses into the US and again each time it crosses a state-line, that single animal might receive a chemical treatment 3 or more times within a matter of a week. The pet industry is strongly opposed to any treatment protocol that would kill an amphibian or shorten its lifespan.
• Based on the language in the Federal Register Notice, it appears that the USFWS would treat the intentional and unintentional movement of amphibians in trade equally – meaning that someone unintentionally moving larvae or eggs in a shipment (e.g., aquatic plants) would be subject to a felony-level violation if they crossed state lines. If a listing proceeds with these conditions, numerous private sector, as well as agency, activities that are not intentionally associated with the amphibian trade would be severely compromised.
• The economic impact of listing all amphibians as injurious unless proven Bd-free could devastate the reptile/amphibian segment of the pet industry. Not only would people be put out of work, but the public would have far less of an opportunity to build an appreciation for amphibians – an appreciation that ultimately translates into a desire to help conserve these and other animals in the wild.
• We question the willingness/ability of the average pet amphibian owner to treat, test, and report Bd prior to relocating their pets across state lines. We further question the ability of state and Federal agencies to enforce the Lacey Act under these circumstances.
• Although pet amphibians are rarely released into the natural environment, hobbyists and pet owners who fear that they would be in violation of the Lacey Act may be inclined to release their amphibians rather than euthanize them. Listing could, thus, foster the conditions that both the USFWS and pet industry would like to prevent.

Your comments must be received or postmarked by December 16, 2010 to Federal eRulemaking Portal: http://www.regulations.gov following the instructions for commenting to Docket No. FWS-R9-FHC-2009-0093 or by U.S. Mail addressed to Attn: Docket No. FWS-R9-FHC-2009-0093, Division of Policy and Directives Management, U.S. Fish and Wildlife Service, 4401 North Fairfax Drive, Suite 222, Arlington, VA 22203.
For further information please contact – Mike Canning by phone at: (202) 452-1525, ext. 108 or via email at: mcanning@pijac.org.
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