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Old 01-24-2012, 03:02 PM   #1
AbsoluteApril
My letter in response to Lacey Act listing

I am sending this letter to my Senators, my Congressman and to the President.

I don’t see this as a partisan issue as I am an independent with strong left/democratic leanings which appears to be opposite a lot of other reptile keepers I see posting comments about ‘vote them out’ on the various forums. All I know is we all need to stand TOGETHER to try to fight this. Renewed my USARK membership again and plan to make another donation this next month. Everyone – keep up the good fight. If anyone wants to use parts of my letter to send your own letters out, please do so. The more they hear from us the stronger we will look.

*********

To: (various as noted above)

I would like to first thank you for taking the time to read this letter. I know that you are extremely busy serving in your elected position.

As a registered voter, I know that my opinion should be of great importance to you. I gave you my vote in the last election but am unsure if I can do so again.

I would like to express my grave disappointment in the announcement made which added 4 species of large constrictors to the Injurious Species list of the Lacey Act. As I'm sure you are aware, USARK (United States Association of Reptile Keepers) has fought hard to oppose this ruling, bringing forth an overwhelming opposition to Congress. Therefore, the Department of the Interior negated the need for a vote from Congress, which would have likely failed. Instead, the pythons were added to the Lacey Act through a rule-making process with little to no regard for public opinion.

It is the job of the White House Office of Management & Budget (OMB) to weigh the purported benefits of the rule against the economic impacts. It is also their duty to assure the rule has been given due process under the Administrative Procedures Act, Information Quality Act and all pertinent Executive Orders. US Fish & Wildlife Service (FWS) grossly underestimated the economic impact. USGS has justified their "science" by saying they were not required to adhere to information quality standards for science used to support the rule because the rule did not meet the standard for a major rule making ($100 million). An economic assessment of the Modern Reptile Industry commissioned by USARK, and done by Georgetown Economic Services, has since debunked USGS claims by asserting that the rule could have impact in excess of $103 million.

The USGS report being used as justification for listing 4 (possibly 9) snakes on the Injurious Wildlife list of the Lacey Act has been discredited by a panel of 11 independent scientists. In a letter to the Senate EPW Committee this report has been characterized as "unscientific". Further the scientists state "this document is not suitable as the basis for legislative or regulatory policies".

 Trade in reptiles and ancillary businesses is estimated to be 3 billion dollars a year
 More than 11 million reptiles are kept as pets in the US (1 in 25 homes)
 The US accounts for 82% of the worldwide trade in reptiles

Thousands are employed directly or indirectly by the reptile industry. The trade in the 4 (possibly 9) snakes addressed in this rule is approximately 1/3 of the total annual trade. In a recent letter to the Senate EPW Committee the US Chamber of Commerce states "if enacted in its current form, this legislation would adversely impact tens of thousands of businesses". Our state alone stands to lose scores of jobs.

Due to the limited environmental conditions these species can tolerate as well as thrive in, they are not pervasive in the majority of the United States, restricted to a small portion of Southern Florida. These species are overwhelmingly tropical animals found mainly in neotropical regions, tropical deciduous forests and jungles from sea level to moderate elevations. They require a permanent water source as excessive dehydration invariably spells death.

I urge you to reverse your decision on the matter. Please look into the biased "science" used to promote Senator Nelson's personal agenda to make a Florida STATE problem a FEDERAL problem.

Thanks you for your time.

Sincerely,

April Yohn
(address here)

Sources:
Debunking the USGS map showing how invasive the species would be: NatGeo report: http://blogs.nationalgeographic.com/...09/12/547.html
Critique of the Analysis Used to Predict the Climate Space of the Burmese Python in the United States by Rodda et al. (2008, 2009) and Reed and Rodda (2009):
http://www.usark.org/uploads/Barkers...itique-002.pdf
Testimony of Mr. Shawn Heflick, Herpetologist before the House Subcommittee on Insular Affairs, Oceans and Wildlife and the House Subcommittee on National Parks, Forests and Public Lands:
http://www.usark.org/uploads/Heflick%20Testimony.pdf
According to a survey done in 2007-2008 “Industry Statistics & Trends" by the American Pet Products Manufacturers Association, Inc., the number of U.S. households that own a reptile numbers at 4.8 (millions). (http://en.wikipedia.org/wiki/Pet#Pet_popularity)
Report “Invasive Non-Native Species: Background and Issues for Congress”
http://www.nationalaglawcenter.org/a...rs/RL30123.pdf
Response from Michael Cota, herpetologist working in SE Asia
“The Giant Snakes” by Clifford Pope, pages 12, 25, 26, 108
 
 


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