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Message from Andrew USARK

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  • Message from Andrew USARK

    I am really upset right now!!! I just went to the government regulations page and saw that 1994 people have made public comment. The problem is 1539 of those comments were actually made in 2008 during the NOI. That means only 455 have been made since the proposed rule was published in the federal register back in March 2010. What is even worse is that half of the 455 are from HSUS and other AR groups. That means that only about 200 members of the Reptile Nation have made comment!!! Why is no one making comment? This is really bad! USARK has been spending thousands of dollars and hundreds of hours fighting this. We need the Reptile Nation to stand up and make comment NOW! DEADLINE is Tuesday May 11, 2010!!

    Go To www.Kill-RuleChange.com and make public comment.



    I have heard a lot of pissing and moaning about unfair legislation and regulation. Venting on a forum will not change one thing out there in the world! What will change things are individuals taking action... Have You Taken Action? Make public comment!!!!!



    Kindest Regards,

    --Andrew

  • #2
    I went to the website a week or so ago to see what was going on. Someone else made a post about the gov't possibly banning certain reptiles. The website might be helping to stop the ban, but its definitely not doing anything to inform the general public of whats going on. I had to go to a gov't site to figure out what the ban was about. In the future it may help the cause to be more informative.
    1.0.0 crested - Cuervo

    Comment


    • #3
      What do you mean more informitive? USARK has this stuff plastered everywhere and it has been for months. The last thing we want is the general public to know. PITA and the HSUS has the general public scared of reptiles especialy after what happened to that little girl back in july.

      Comment


      • #4
        By more informative I mean that the website could provide more facts pertinent to the situation.
        1.0.0 crested - Cuervo

        Comment


        • #5
          Theres plenty of facts all over the USARK website.

          Comment


          • #6
            I've said it before, crested geckos and all other repiles are next, please take the 5 minutes to do this.

            Copy and Paste the sample letter into the form located here

            Fill in the fields for Name, Country, City and Postal Code. Ignore the rest of the fields.


            Sample Letter (add your own comments if possible)

            U.S. Fish and Wildlife Service
            Division of Policy and Directives Management
            Attn: Docket No. FWS-R9-FHC-2008-0015
            4401 N. Fairfax Drive, Suite 222
            Arlington, VA 22203

            RE: Docket No. FWS-R9-FHC-2008-0015

            Dear U.S. Fish and 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 proposed rule to list nine species of large constrictor snakes as injurious (75 Fed. Reg. 11808-11829 (March 12, 2010)).

            CONTROVERSIAL
            As you know, in 2009 the U.S. Geological Survey (USGS) released a highly controversial report on nine snake species. This internal report was NOT peer reviewed science. It is riddled with mistakes, inaccuracies, misrepresentations and unsupportable assumptions. The USARK has filed a 36 page Request for Correction with the USGS under the Information Quality Act. In a letter to the Senate Environmental & Public Works Committee a panel of 11 acclaimed scientists called the report “not scientific” and “not suitable as the basis for legislative or regulatory policy”. This poorly done report is the only “science” that supports the proposed rule.

            UNPRECEDENTED
            If enacted, this rule making would have the unprecedented effect of putting as many as a million American citizens in possession of Injurious Wildlife and subject to potential felony prosecution under the Lacey Act. It could effectively create a new class of criminal out of law abiding American citizens. Never has the USFWS attempted to list such a large group of animals that are widely held by the American public.

            SIGNIFICANT ECONOMIC IMPACT
            USFWS does not possess the information needed to do a credible Initial Regulatory Flexibility Analysis (IRFA) on proposed rules regarding constrictor snakes. In its report, dated February 10, 2010, USFWS relied on baseless assumptions and extrapolations and it ignored information submitted by industry participants and trade associations in response to its 2008 Notice of Inquiry. In addition, the Service misused the information it was provided by respondents to the notice. Therefore, the Service’s regulatory flexibility analysis is not a complete, reliable, or convincing analysis of the impact of the proposed rule on small businesses involved in the buying and selling of the nine snake species included in the proposed rule. The IFRA grossly underestimates the scope of the impact of the proposed regulations.

            ALTERNATIVES
            USFWS has failed to explore suitable alternatives to Lacey Act listing. There is a plethora of ideas on how to address the issue of invasive species that are for more pragmatic and less damaging than the Lacey Act. It was the consensus opinion at the recent US House Committee on Natural Resources Hearing on Invasive Species that Lacey Act was an ineffectual tool for addressing this issue. State/Local Risk Assessment combined with industry Best Management Practices (BMP) was suggested by Dr. Frank Mazzotti of the University of Florida. (His is a unique perspective because he is the one responsible for the radio tracking of pythons in the Everglades National Park.) USARK has developed an Accreditation utilizing BMP’s that have passed into state law in North Carolina and are currently pending in SC. They are also being considered by GA, LA, CA and VA. USFWS has an obligation to explore viable alternatives. To date they have not.

            It is clear that the USFWS has not thoroughly considered the full implications this proposed rule making would have. Further it is clear that USFWS has not given the due diligence required to enact such a controversial, unprecedented and draconian measure. It is clear that if enacted the proposed rule would negatively impact as many as a million Americans. The limited effectiveness of the Lacey Act as a means to control invasive species means that if enacted the stated intent of the rulemaking would never be realized. Nothing would change on the ground in south Florida. The only effect would be to destroy the captive propagation and trade of animal's already in captivity all across the country.

            Please stop the proposed rule to restrict the trade in nine species of constrictors.

            Thank you for your consideration.

            Comment


            • #7
              I did it! Thanks for providing the link and example letter!
              Mrs. Smith's Geckos
              My iherp
              Facebook
              https://www.morphmarket.com/stores/mrssmithsgeckos/
              Many crested geckos, 0.1 leachie, 1.1 Hog Island boas, 0.0.3 Phyllobates terribilis, 1.1 cats, and 0.1 dog. One husband and one four year old.

              Comment


              • #8
                I did it too. Thanks
                www.emilymaple.com

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