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Thread: ALERT: DEADLINE Public Comment Amphibian Listing!

  1. #1
    Website Admin Bell's Avatar
    Join Date
    Feb 2008
    Colorado Springs

    ALERT: DEADLINE Public Comment Amphibian Listing!

    This is from a letter from USARK:

    Quote Originally Posted by USARK
    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 -------- ... 6480bb062b

    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.

  2. #2
    Website Admin Bell's Avatar
    Join Date
    Feb 2008
    Colorado Springs

    Re: ALERT: DEADLINE Public Comment Amphibian Listing!

    I would like to note that as of now this is only a petition to gather more information:
    We, the U.S. Fish and Wildlife Service (Service), are reviewing a petition to list, under the Lacey Act, all live amphibians or their eggs in trade as injurious unless certified as free of Batrachochytrium dendrobatidis (chytrid fungus).
    An injurious wildlife listing would prohibit the importation of live amphibians or their eggs infected with chytrid fungus into, or transportation between, States, the District of Columbia, the Commonwealth of Puerto Rico, or any territory or possession of the United States by any means, without a permit.
    What the FWS is specifically wanting comments on are as follows:
    Quote Originally Posted by FWS
    We are soliciting information and supporting data from the public to gain substantive information, and we specifically seek information on the following questions regarding the importation of live amphibians and their eggs infected with Batrachochytrium dendrobatidis (chytrid fungus):
    (1) What Federal, State, or tribal regulations exist to prevent the spread of chytrid fungus?
    (2) Are there any known mechanisms in the United States to test for, control, or regulate movement or interstate transport of chytrid fungus?
    (3) How many businesses import live amphibians or their eggs into the United States?
    (4) How many businesses sell live amphibians or their eggs for interstate commerce?
    (5) What are the annual sales of these imported live amphibians and their eggs?
    (6) What species of amphibians, fish, or other class of animal have been affected by chytrid fungus in the United States and how were they infected?
    (7) What are the current and potential effects to species listed as threatened or endangered under the ESA that are contaminated with chytrid fungus?
    (8) What are the potential costs of recovering threatened or endangered species affected by chytrid fungus?
    (9) What is the likelihood that wild amphibians would be affected by the importation of live amphibians or their eggs that harbor chytrid fungus?
    (10) What would it cost to eradicate chytrid fungus?
    (11) Are there any potential benefits to allowing the chytrid fungus pathogen to be imported?
    (12) What is the potential for the industries that conduct trade in amphibians to self-police through voluntary best practices; for example, how successful is the ``Bd-Free `Phibs Campaign'' sponsored by the Pet Industry Joint Advisory Council?
    (13) What peer-reviewed methods for detecting chytrid fungus have been published?
    (14) Are there any other comments or information regarding the listing of live amphibians as injurious unless free of chytrid fungus?
    This petition was initiated by the Defenders of Wildlife.

    And some additional sites to increase your knowledge on the chytrid/BD fungus and its affect:
    Bd-Free 'Phibs Campaign
    Amphibian Ark

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