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Proposal to Update Part 23
Attached are AFC's comments to the Fish and Wildlife Service's proposal to update Part 23, our U.S. CITES regulations. Please take time to read through this and feel free to comment on the proposed changes yourself, using this document as a guide if it's helpful. Comments must be made by May 7, 2012.
Thanks.
Bill Meeker
President, AFC
Note: You can also find the article in our website www.falconryconservancy.org
This letter is a great read and an education in it's self. It contains information that every falconer should know.
I don't see the attachment?Quote:
Originally Posted by sharptail
Hi Fred,Quote:
Originally Posted by FredFogg
Try under the Legal tab at the top of the page, it worked for me, just now.
Ok, found it. Thanks, I will read it this evening.Quote:
Originally Posted by sharptail
My brain is bleeding from all that gobbly gook. Let's just make it easier and dump CITES.
AFC wrote a very good letter a little wordy but good. I hope everyone sends a comment to USFWS before May 7th.
Mark
laQuote:
Originally Posted by sharptail
Thank you Mark. Would you care to post your letter?
Trade in Raptors is an international issue and I would like to invite all potential trade partners world wide to participate in this invitation to comment.
Comments may be made electronically.
Electronically: Go to the Federal
eRulemaking Portal: http://
www.regulations.gov. In the Keyword
box, enter Docket No. FWS–R9–IA–
2010–0083, which is the docket number
for this rulemaking. Then, in the Search
panel on the left side of the screen,
under the Document Type heading,
click on the Proposed Rules link to
locate this document. You may submit
a comment by clicking on ‘‘Send a
Comment or Submission
Not much time left to respond on this issue.
The word that I am getting is that the US CITIES Office has been far more restrictive to US citizens in issuing permits for the export of raptors then is called for, by the CITIES Secretariat. It is far more restrictive to Raptor breeders, than breeders of other forms of wildlife and plants leaving the US. It is far more restrictive than other nation's CITIES Offices are to their Citizens or would be to our breeders, without US CITIES influence. The US CITIES Office insists that other countries treat US Exporters and Foreign Importers of Raptors more harshly than they would without the US Office's influence. This has put our Raptor breeders at a distinct disadvantage over their competition across the globe and has nearly put some of our breeders out of business.
Since Domestic bred Raptors reduce the demand for, and therefore pressure on wild raptor populations, breeders are providing for Ecology of wild raptor populations. The US CITIES position, on being more restrictive than need be, voids this Ecology enhansing contribution of the raptor breeding community
After reading NAFA's draft response, it was, although along the same vein, a rather 'rose water weak' reply. I hope that the final product shows a little more 'Brass', something that NAFA has all too often lacked in dealing with what the FWS wants. This goes against the grain of, what I too often see, in US Falconers being treated like Second Class Citizens by it's own gov't, with NAFA support .
One sure way to make your voice heard is to comment yourself as an individual and not rely on others that may not support your rights and best interests.
Quote:
Originally Posted by sharptail
Jeff,
Please do not turn NAFEX into a battle ground. I appreciate your passion on the issue. We often have to bow to diplomacy rather than fight the fight we want to with every encounter. Please refrain from bashing NAFA even if you feel it is warranted. NAFEX is not the proper venue for this. I allow each of the national organizations on NAFEX as a courtesy to disseminate information that is germane and non confrontational. Please use NAFEX in a positive manner.
Thank you for understanding.
Chris
Sorry to offend Chris.
Hi Jeff,Quote:
Originally Posted by sharptail
No Offense at all and thanks for taking the time to make everyone aware of the issues at hand. I know how important these issues are and how much they mean to us all. My post was made as I don't want the value of your thread to be driven down by everyone bickering over if NAFA does a good job or not. I value each organization, AFC and NAFA, for what they are. Each has their own style and agenda. What would make me happier than a pig in Sh_t is to see more unity and less division... I digress.... Get your comments in everyone!!!
Kindest regards
Chris
Chris,Quote:
Originally Posted by Chris L.
I think what Jeff is trying to get across is by restricting the issue of cites to a limited number of breeders in the US it is then a restrict of trade,more and more breeders are tapping into the middle eastern market and making big money out of it and fair play to them times are hard and friends are few,if NAFA's there to help US falconers then it should get behind its members and help them,over here in the UK we have the Hawk Board which is the elected mouth piece for UK falconers,most serious falconers over here would like a wild take on raptors again due to numbers being at record levels but sadly the Hawk Board is made up of breeders and its a case of over our dead body and are not willing to give any ground on it,forums do'nt need to be confrontational but all the same we need the backing of our organisations and not have them sit twiddling their fingers or is because of other motives like over here.
regards Daryl,
You get more flies with HONEY!
Today is the last day, get your comments in.Quote:
Originally Posted by sharptail
Moglich Longwings
Mark Moglich
949 Bar J Rd
Gardnerville, NV 89410
Phone 775-901-6640
gyr@clearwire.net May 3,2012
Service Information Collection Clearance Officer
US Fish and Wildlife Service
MS 222-ARLSQ
Arlington, VA 22203
RE: 1018-AW82
Ladies and Gentleman:
I Have been a licensed Raptor Breeder in the US since 1993 and a CITES registered breeding Operation since 2008. I appreciate the opportunity to comment upon the proposed information collection aspects of rule changes implementing cops 14 and 15 of CITES. As a member of the American Falconers Association I stand by their comments as well. I don’t stand by NARBA comments in regards to renewal.
US regulations stricter than those required by CITES do not provide better protection for the resource and, in fact, harm wild raptor populations. Producing captive bred raptors reduces pressure on Wild take and thus a great asset to the protection of the Wild Populations. We are business people working hard raising a captive bred resource, which is, and should be viewed in a positive light by the US Fish and Wildlife Service.
Regarding the proposed renewal of CITES registration every five years, CITES regulations do not require renewal for registrations, and registrations do not expire. The proposed renewal is more restrictive than CITES it self and serves no purpose. All the information on our breeding activity is reported to Migratory bird offices every year and that should suffice. Requiring more than CITES requires is for no purpose and since only one or two biologist work on raptor permits at OMA taking some permits as long as 6 months or more and some previous CITES registration applicants as long as 2 years, how can the Service renew CITES every 5 years? If the OMA were so behind on processing permits why would it want to increase its workload even further when its not even required by CITES? What’s the purpose for this proposed additional regulation that CITES does not require nor do other CITES countries require? This will only delay breeders being able to trade their stock and cause financial burden on the breeder. Renewal during breeding season and waiting for long processing renewals would be a great burden and cause breeders financial hardship.
If the US FISH and Wildlife insist on a 5 year renewal and wishes to scrutinize breeders each 5 years then the Service needs to send us their written criteria that they add above CITES regulations in advance. Changing criteria without notice then later saying you don’t meet the criteria would be injustice to say the least.
Is the Service looking to help Raptor breeders or thin them out?
Is requiring all this additional renewal red tape “Saving Wildlife”?????
Thank you for considering my comments.
Sincerely,
Mark Moglich
Raptor Breeder
Quote:
Originally Posted by sharptail