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Thread: AFC CITIES comment letter. Comments due 5/7/12

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  1. #1
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    Default AFC CITIES comment letter. Comments due 5/7/12

    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
    Jeff,
    Northern Black Hills, Wyoming

  2. #2
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    Default

    This letter is a great read and an education in it's self. It contains information that every falconer should know.
    Jeff,
    Northern Black Hills, Wyoming

  3. #3
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    Default

    Quote Originally Posted by sharptail View Post
    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
    I don't see the attachment?
    Fred
    "Adopt the pace of nature: her secret is patience." ~Ralph Waldo Emerson

  4. #4
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    Quote Originally Posted by FredFogg View Post
    I don't see the attachment?
    Hi Fred,
    Try under the Legal tab at the top of the page, it worked for me, just now.
    Jeff,
    Northern Black Hills, Wyoming

  5. #5
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    Quote Originally Posted by sharptail View Post
    Hi Fred,
    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.
    Fred
    "Adopt the pace of nature: her secret is patience." ~Ralph Waldo Emerson

  6. #6
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    My brain is bleeding from all that gobbly gook. Let's just make it easier and dump CITES.
    Pete J
    It's all just too Zen for me.

  7. #7
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    Default USFWS COMMENT Period

    AFC wrote a very good letter a little wordy but good. I hope everyone sends a comment to USFWS before May 7th.

    Mark

    la
    Quote Originally Posted by sharptail View Post
    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
    Mark Moglich
    americangyrs.com

  8. #8
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    Thank you Mark. Would you care to post your letter?
    Jeff,
    Northern Black Hills, Wyoming

  9. #9
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    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.
    Jeff,
    Northern Black Hills, Wyoming

  10. #10
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    Default How 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
    Jeff,
    Northern Black Hills, Wyoming

  11. #11
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    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.
    Jeff,
    Northern Black Hills, Wyoming

  12. #12
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    Default Now is the time

    Quote Originally Posted by sharptail View Post
    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
    Today is the last day, get your comments in.
    Jeff,
    Northern Black Hills, Wyoming

  13. #13
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    Default

    You get more flies with HONEY!
    Caleb Stroh
    Kaysville, UT

  14. #14
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    Default my comments

    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 View Post
    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
    Mark Moglich
    americangyrs.com

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