Public Comment USFWS Rule Change

Public Comment USFWS Rule Change
The following are guidelines from USARK to the Reptile Nation on “How to” make an effective and highly impactful public comment on the USFWS proposed ‘Rule Change’. If enacted ‘Rule Change’ could add 4 pythons, 4 anacondas and Boa constrictor to the Injurious Wildlife list of the Lacey Act. It is very important that your public comment be thoughtful and pertinent. During the Notice of Inquiry in 2008 only 115 public comments out of approximately 1500 were used because most failed to answer what was asked by USFWS.

USARK Recommendations on Making Public Comment:

1. Do Not plead for your animals and write how unfair this is.
2. Do Not give your political philosophy or your feelings about government regulation.
3. There is a list of questions that should be addressed if you have the knowledge to address them. Look for USARK suggestions in italics. Answer only questions you feel comfortable and knowledgeable on.
4. Be thoughtful and as original as possible with your comments.
5. Comment on the effectiveness of using the Lacey Act.
6. Give alternatives to Lacey Act. (such as USARK Industry Best Management Practices...USARK Accreditation)
7. Comment on the unprecedented nature of listing animals that are so widely held by American public. (use the word ‘unprecedented’)
8. Unintended consequences of reducing the value of as many as 2 million animals to $0 overnight. What will happen to animals that owners can no longer afford to care for?
9. The fact that USFWS has done such a poor job making their scientific and economic case has created a highly controversial situation. Many credible scientists, economists and industry leaders disagree with USFWS. (use the word ‘controversial’)
10. Comment on the economic impact on you and your family.

Click here to make public comment: http://www.regulations.gov/search/Re...00006480abc25c

USFWS Questions to be Answered by Public Comment:

(1) What regulations does your State have pertaining to the use, transport, or production of any of the nine constrictor snakes? What are relevant Federal, State, or local rules that may duplicate, overlap, or conflict with the proposed rule?
(2) How many of the nine constrictor snakes species are currently in production for wholesale or retail sale, and in how many and which States? (Burmese python, reticulated python, northern African python, yellow anaconda, green anaconda and Boa constrictor. Which ones are in your state?)
(3) How many businesses (do you?) sell one or more of the nine constrictor snake species?
(4) How many businesses (do you?) breed one or more of the nine constrictor snake species?
(5) What are the annual sales (your sales) for each of the nine constrictor snake species?
(6) How many, if any, of the nine constrictor snake species are permitted within each State? (are they banned in your state?)
(7) What would it cost to eradicate individuals or populations of the nine constrictor snakes, or similar species, if found? What methods are effective? (unless you are in south Florida $0, because there is NO evidence they can live in your state)
(8) What are the costs of implementing propagation, recovery, and restoration programs for native species that are affected by the nine constrictor snake species, or similar species? (unless you are in south Florida $0, because there is NO evidence they can live in your state)
(9) What State threatened or endangered species would be impacted by the introduction of any of the nine constrictor snake species? (unless you are in south Florida NONE, because there is NO evidence they can live in your state)
(10) What species have been impacted, and how, by any of the nine constrictor snake species? (unless you are in south Florida NONE, because there is NO evidence they can live in your state)
(11) What provisions in the proposed rule should the Service consider with regard to:
(a) The impact of the provision(s) (including any benefits and costs), if any, and
(b) What alternatives, if any, the Service should consider, as well as the costs and benefits of those alternatives, paying specific attention to the effect of the rule on small entities?
(12) How could the proposed rule be modified to reduce any costs or burdens for small entities consistent with the Service’s requirements? (allow for interstate trade in captive bred animals to continue)
(13) Why we should or should not include hybrids of the nine constrictor species analyzed in this rule, and if the hybrids possess the same biological characteristics as the parent species.

USARK is Investing Thousands of Dollar$ Challenging 'Rule Change'

• We Hired an Independent Economist to do an Economic assessment of the Industry.
• We Hired an Attorney in anticipation of the need to file a lawsuit against USFWS.
• We are doing extensive scientific research to counter the poor work USGS has done.

****Please go to USARK.org to donate and help us pay for Challenging Rule Change!****

There Is Strength in Numbers... Protect Your Rights! We can win this fight!!

I have some questions : Is question 2 asking for my business specifically ? Because it would be unrealistic for me to know how many breeders and animals are produced..In questions 3-5 I would assume are directed toward each business indivually ...problem is I have several of these species growning for production and they have not reached breeder size yet but I do have money invested for future production which needs to be addressed in question 5. any educated assistance would be appreciated...thanks in advance

Hi Wayne,
I'll do my best to answer each of your questions, but if you have any follow up questions, or I miss one, feel free to post a follow up message

The information that the USFWS is looking for is VERY "birds-eye view" of the reptile industry. USARK is handling that so don't worry about that. What my recommendation would be is to say that you do not have the large scale information requested, but that you can offer what this means to you.

So for question 2, I would recommend something like this (but use your own words):
(2) How many of the nine constrictor snakes species are currently in production for wholesale or retail sale, and in how many and which States?
I do not have information for the rest of the US, but my business currently produces ___# of ____, ___# of ____, etc. I sell these animals to customers in the contiguous United States (and internationally if applicable). Over the next 3 years, I anticipate growing my business to produce ___# of ___, etc..

For question 5 I would list what your sales are per species last year, estimated for this year, and maybe the next two if that'll help to demonstrate your investment. I would also explain why (that you have animals/investments maturing).

For questions 3 and 4, answer them from your perspective and include something similar to question 2 to explain the rest.

Hope that helps!
jb

Thanks that helped alot.