ALERT: USARK Challenge/USFWS Rule Change - FaunaClassifieds
FaunaClassifieds  
 Sponsors »  Breeders | Dealers |  Importers/Exporters | Caging | Feed | Supplies | Services | Events 
  Inside FaunaClassifieds » Product Reviews |  Classifieds!   | Photo Gallery   | Banner Advertising 
 
  Do you want to be able to bump and highlight your classified ads? Click here!

Go Back   FaunaClassifieds > Laws, Legislative Issues & Alerts > General Legislative Discussions

Notices

General Legislative Discussions Any general discussion concerning legislative issues or events. Not necessarily specific to a particular region, or even a type of animal group.

Reply
 
Thread Tools Display Modes
Old 05-05-2010, 09:13 PM   #1
USARK.Jonathan.Brady
ALERT: USARK Challenge/USFWS Rule Change

ALERT: USARK Challenge/USFWS Rule Change
As we have stated previously, successfully challenging the USFWS Proposed Rule Change that could add 9 constrictor snakes to the Injurious Wildlife list of the Lacey Act involves a multi- pronged strategy. This strategy is currently being implemented by USARK in coordination with coalition partners representing various like-minded constituencies. Making public comment is vitally important, but just one piece of our strategic plan. Here is a brief overview of the necessary steps as we see them.

1. Make Public Comment to USFWS: Deadline Tuesday May 11, 2010: USARK has requested a 90 day extension (we have it on authority that our request will be denied). Please comment ASAP! Go to www.Kill-RuleChange.com for guidelines on making comment.
2. Challenge USFWS Initial Regulatory Flexibility Analysis (IRFA): IRFA is the USFWS economic analysis. Although USARK is spearheading an independent Economic Assessment of the entire reptile industry with a Georgetown firm, our job at present is to show the problems with the USFWS assessment- Click here to read USARK IRFA Response: http://www.usark.org/uploads/Respons...FWS%20IRFA.pdf.
3. Challenge the USGS report on constrictor snakes under the Information Quality Act (IQA): The IQA requires that when federal agencies consider regulation that is unprecedented, controversial and/or would have significant economic impact, that they be held to a very high standard as to the quality of information used to support such regulation. It also requires all alternatives be considered. We believe USGS/ USFWS have failed on all accounts- Click here to read USARK IQA Challenge: http://www.usark.org/uploads/USARK%2...0Challenge.pdf.
4. Prepare a Superior Alternative: USARK is working with state wildlife agencies and leading academics to set up a State/ Locality based Risk Assessment and industry Best Management Practices as an alternative to Lacey Act listing.
5. Prepare to file a Federal Lawsuit: In anticipation that USFWS ignores the fact that there are gross inequities, misrepresentations and inaccuracies in the Proposed Rule and agency reports used to support the Proposed Rule. There are also alternatives that have not been fully explored.

Although each step is interrelated and extremely important, one of the most crucial parts of this puzzle is the IQA Challenge. Our IQA document was prepared by the same person handling the most prominent IQA challenge in the country, which many of you may know involves the delta smelt in the central California valley. Although some have characterized our challenge as being too critical of government agencies, USARK disagrees. We believe that the agencies involved have done an extremely poor job of supporting their position, and our IQA challenge will bring that point to the fore and establish it as part of the public record. Our IQA document is in large part the product of a coalition effort that USARK has been engaged in for roughly four months. If we are successful then it is likely the focus will move to our proposed alternative.

The most immediate need is for Reptile Nation to make public comments on the proposed rule. Groups advocating this “snake ban” have their members engaged and producing comments in large numbers. It is therefore essential we get our folks engaged and that everyone go online and submit comments. Please make those Public Comments prior to the DEADLINE of May 11th! We have set up a page on the USARK website to help you along. Please visit www.Kill-RuleChange.com for suggestions for your consideration.
 

Join now to reply to this thread or open new ones for your questions & comments! FaunaClassifieds.com is the largest online community about Reptile & Amphibians, Snakes, Lizards and number one classifieds service with thousands of ads to look for. Registration is open to everyone and FREE. Click Here to Register!

 
Reply

Thread Tools
Display Modes

Posting Rules
You may not post new threads
You may not post replies
You may not post attachments
You may not edit your posts

BB code is On
Smilies are On
[IMG] code is On
HTML code is Off

Similar Threads
Thread Thread Starter Forum Replies Last Post
Kill Rule Change Message from Andrew USARK.Jonathan.Brady General Legislative Discussions 0 05-05-2010 09:05 PM
Public Comment USFWS Rule Change USARK.Jonathan.Brady General Legislative Discussions 3 04-20-2010 06:31 PM
From USARK: Re: USFWS Comment Period USARK.Jonathan.Brady General Legislative Discussions 1 04-02-2010 01:40 PM
WARNING: Proposed Rule Change/ USFWS USARK.Jonathan.Brady General Legislative Discussions 0 03-11-2010 05:03 PM
Proposed Rule Change Delayed USARK.Jonathan.Brady General Legislative Discussions 0 02-16-2010 08:51 PM


All times are GMT -4. The time now is 09:48 PM.







TESTING!
Fauna Top Sites


Powered by vBulletin® Version 3.7.3
Copyright ©2000 - 2021, Jelsoft Enterprises Ltd.
Page generated in 0.06150603 seconds with 10 queries
Content copyrighted ©2002-2018, FaunaClassifieds, LLC