ACTION NEEDED! Constrictor Rule Updates

Discussion in 'Reptile Law & Legislation' started by JEFFREH, Jun 27, 2014.

  1. JEFFREH

    JEFFREH Administrator Staff Member

    **Forwarded from USARK - Even if you do no not keep snakes, it is important to do your share for the hobby. It takes only a few minutes to do your part! The more momentum these anti-pet groups gain the more species they can attack. We need to stand together as herp enthusiasts and support one another even if we keep different things! The addition of these species to the Lacey Act is completely unfounded, don't let them take away our rights...Please read and leave your comment!*


    Constrictor Rule Comment Reopens
    Request an Extension for Comment Now

    Deadline is July 24: Fish and Wildlife Service (FWS) is taking additional comments regarding listing five species of snakes (Boa constrictor, Reticulated python, DeSchauensee’s anaconda, Green anaconda and Beni anaconda) as injurious under the Lacey Act. These species were originally proposed in 2010. If listed, FWS would ban interstate transportation/commerce and importation. Remember to be professional and civil with your comments.

    At this time, everyone should send a first round of comments requesting an extension of the comment period. These can be relatively simple and Talking Points are below. The Association of Zoos and Aquariums (AZA) and the Pet Industry Joint Advisory Council (PIJAC) will also be requesting an extension. All affected groups, businesses and individuals are encouraged to do the same. FWS has allowed only 30 days for comment, which is inadequate.

    Comments must be submitted at: www.regulations.gov/#!submitComment;D=FWS-R9-FHC-2008-0015-4570or by visitingwww.regulations.gov/#!documentDetail;D=FWS-R9-FHC-2008-0015-4570 and clicking Comment Now! in the upper right.

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

    The letter for an extension of the comment period by USARK can be viewed at www.usark.org/wp-content/uploads/2014/06/USARK_Request_for_Extension.pdf.

    USARK Talking Points for Extension Request

    A significant amount of time has passed since the last opportunity for public comment closed in 2010.
    Substantial new biological and economic information is available since the end of the last comment period.
    The proposed listings will have severe educational, economic, conservation and scientific impacts, and therefore adequate time for submissions is necessary.
    Reptile owners are a diverse group, so extra time is needed to ensure that all concerns are heard. This is particularly true for military service members.
    Tens of thousands of responsible pet keepers will also be negatively affected.

    The Federal Register announcement can be viewed at www.usark.org/wp-content/uploads/2014/06/Constrictor-Rule-Register-6.24.14.pdf.
     
    carlene pool likes this.
  2. JEFFREH

    JEFFREH Administrator Staff Member

    DEADLINE JULY 24!

    Constrictor Rule

    By USARK on June 27, 2014
    Comment Now
    All Americans who appreciate their freedom to have pets should comment. This may only affect big snake keepers now, but any species could be the next target. The entire pet community is being picked apart as we are not supporting each other in protecting our freedoms. Support your pet and reptile community and comment today! Over 80 million American households have pets. Over five million of those have pet reptiles. There should be tens or hundreds of thousands of comments made against adding additional species to the Constrictor Rule. This needs to be shared! Below are Talking Points, comment links, mailing address, sample letter, FAQ and more.
    Deadline is July 24 (no extension): Fish and Wildlife Service (FWS) is taking additional comments regarding listing five species of snakes (Boa constrictor, Reticulated python, DeSchauensee’s anaconda, Green anaconda and Beni anaconda) as injurious under the Lacey Act. These species were originally proposed in 2010. If listed, FWS would ban interstate transportation/commerce and importation. Remember to be professional and civil with your comments.


    Comments must be submitted at www.regulations.gov/#!documentDetail;D=FWS-R9-FHC-2008-0015-4570 and clicking Comment Now! in the upper right. You may also comment at www.regulations.gov/#!submitComment;D=FWS-R9-FHC-2008-0015-4570.

    Key Talking Points(These can be used in your comments. Personalize all comments, but you may copy/paste these to strengthen your statement. If unsure how to copy/paste, see bottom of this page.)
    • The species in review should not be classified as “injurious.” Any studies, including the USGS study, that originally prompted the listing have been discredited and contradicted in the time since the original proposal. Today, the best science available has demonstrated that none of these species are biologically suited to survive beyond southernmost Florida.
    • It has been determined that Boa constrictors cannot survive the colder temperatures outside of southern Florida.
    • Reticulated pythons demonstrate that they are especially fragile and temperature sensitive during egg incubation. As a result, there is no chance of these species establishing themselves in the wild and there are no populations in the U.S.
    • Extreme South Florida provides the only possible habitat for these animals and the State wildlife authorities have already taken measures to manage and control trade and prevent accidental introduction. A federal ban on interstate activities is an unnecessarily overreaching and extreme response that impacts the livelihoods and pet choices of Americans in the other 48 continental states.
    • The interstate transportation ban is draconian because it prohibits moving an animal just a few feet, from one state where ownership is legal to another state where ownership is legal. Even a trip across town with a pet could constitute a federal crime in greater metro areas. This is an overwhelming injustice on the right to travel for Americans.
    • This listing would have a hugely negative economic impact on family-owned businesses across the U.S.
    • This listing will impact pet owners, veterinarians, zoos, educational organizations, breeders, and others.
    • Studies have shown that up to $100,000,000 annually would be lost in direct revenue in the pet industry by listing these species. Jobs and businesses will be lost as a result.
    • The impact will be felt disproportionately by tens of thousands of families, including those in military service, that already hold these snakes as pets.
    • There will be a lost education opportunity for the public. For this reason, a huge and diverse group of stakeholders opposes the listing.
    Additional Talking Points
    • Temperature extremes were completely ignored in the USGS paper used to propose these species as injurious. Extremes are much more relevant than temperature means.
    • These tropical species of snakes do not have natural hibernation instincts. They do not seek refuge as temperatures drop and this has been scientifically proven.
    • Boa constrictors are native into the Sonoran Desert of northern Mexico. They cannot survive the lower temperatures or populate into the U.S. north of their natural range. If they could be invasive into the U.S., they would have already established over a large portion.
    • A breeding population of Boa constrictor has been noted on the Deering Estate since the 1970s. In over 40 years, the snakes have not moved outside of the original parcel of land and struggle to survive.
    • These species all have very unique biological traits. They vary greatly from each other and also from the snake species that have already been listed as injurious.
    • The proposal to list these snakes under the federal Lacey Act was opposed by a wide group of stakeholders, including the Association of Zoos and Aquariums (AZA), the Association of Fish and Wildlife Agencies (AFWA), the pet industry, and the Small Business Administration Office of Advocacy, to name a few.
    • Listing these species as injurious will risk pet welfare and health as transportation to the nearest or specialized veterinarian, which may be across a state border, would be illegal.
    • Boa constrictors, Reticulated pythons and Green anacondas are often used for educational outreach programs with presenters often travelling between states.
    • The proposal was highlighted in a House Oversight and Government Reform hearing as federal overreach and at a House Natural Resources Committee hearing which featured National Geographic’s resident herpetologist in opposition to the listing.
    • This rule is an unnecessary federal intrusion into state wildlife management and misuse of the Lacey Act.
    • There is no valid scientific evidence to support the listings.
    Sample CommentPlease modify your comment by personalizing it and using other/additional Talking Points.

    There is no valid, peer-reviewed science to support adding species to the Constrictor Rule. As an American citizen, I oppose the listing of any additional species of constrictor snakes, including Boa constrictor, Reticulated python, DeSchauensee’s anaconda, Green anaconda and Beni anaconda, as injurious under the Lacey Act. Any studies, including the USGS study, that originally prompted the listing have been discredited and contradicted in the time since the original proposal. Today, the best science available has demonstrated that none of these species are biologically suited to survive beyond southernmost Florida.

    Listing additional species will harm animal welfare and destroy education programs, conservation efforts and family businesses. Even a trip across town with a pet could constitute a federal crime in greater metro areas. This is an overwhelming injustice on the right to travel for Americans.

    A significant amount of time has passed since the last opportunity for public comment closed in 2010. Substantial new biological and economic information has become available since then. The proposed listings will have severe educational, economic, conservation and scientific impacts. This affects tens of thousands of American families and is based upon bad science. Listing additional species will not protect the environment but it will destroy American freedoms, families and businesses. I appreciate your time to review my comment and make the correct decision by not adding additional species. Any other decision would be an unconstitutional and overreaching infringement on my freedoms as an American.

    Sample Letters
    Four sample letter can be downloaded at www.usark.org/library/constrictor-rule-letter-1/.
     

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