949 Bar J Rd
Gardnerville, NV 89410
email@example.com May 3,2012
Service Information Collection Clearance Officer
US Fish and Wildlife Service
Arlington, VA 22203
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.
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