ALERT: DEADLINE Public Comment Amphibian Listing!
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.