In an unprecedented move, the U.S. Fish and Wildlife Service has empowered itself to shortcut the rule making process under the Lacey Act in order to more easily and arbitrarily declare “Injurious Wildlife” listings, and making way for the potential mass listing of species. Known as CatX, this newly enacted rule will negatively impact zoos and aquariums, research facilities, TV and film, aquaculture, herpetoculture, and the pet trade.
What is a Categorical Exclusion (CatX)?
The U.S. Fish and Wildlife Service (FWS) states:
A categorical exclusion is a class of actions under the National Environmental Policy Act (NEPA) that do not individually or cumulatively have a significant effect on the human environment. Under NEPA, Federal agencies are required to consider the potential environmental impact of agency actions prior to implementation. Agencies are then generally required to prepare either an Environmental Assessment (EA) or an Environmental Impact Statement (EIS). However, when a Federal agency identifies classes of actions that under normal circumstances do not have a potentially significant environmental impact, either individually or cumulatively, the Council on Environmental Quality (CEQ) regulations allow the agency to establish a categorical exclusion and to bypass the completion of an EA or an EIS when undertaking those actions.
Will 5 More Constricting Snakes be Added
to the Injurious Wildlife List?
The US Herpetoculture Alliance alerted the reptile community back in May that US Fish and Wildlife Service (FWS) planned to re-open the public comment period regarding the “Constrictor Rule.” On June 23rd FWS officially announced the re-opening of a 30 day public comment period as expected; deadline of July 24th at 11:59pm EDT. Herp Alliance filed detailed public comments prior to the deadline. Did you make public comment? Please share your official comment in our comment section below.
In January 2012 FWS published a rule in the Federal Register that added the Burmese python, Indian python, northern and southern African pythons, and the yellow anaconda to the Injurious Wildlife List of the Lacey Act. The Constrictor Rule added 5 of the 10 snakes originally proposed for listing, however five remaining snakes (Boa constrictor, reticulated python, green anaconda, DeShauensee’s anaconda and Beni anaconda) were not listed at that time, but remained “under consideration.”
Although the reopening of public comment was welcome news and an additional opportunity to provide critical information for the public record, the Herp Alliance believes this action is a clear signal that FWS is prepared to finalize the Constrictor Rule that was finalized in part on January 23, 2012 (77 FR 3330)– adding some or all of the remaining five species of constricting snakes to the Injurious List. Any species listed on the Injurious List cannot be imported into the country nor transported across state lines without a special permit from FWS.
The US Herpetoculture Alliance filed detailed public comment with FWS opposing the proposed rule to add the remaining five species to the Injurious list. We urge you to read them. Our argument focused on the “best available economic and scientific data” and pointed out the egregious flaws in the FWS justification for rule making. Some of the points included:
Best Available Science
Arbitrary and Capricious
Additionally, Herp Alliance worked with the best and the brightest in the scientific and legal community coordinating many high quality comments. Please read our public comment and post your thoughts below in our comment section. If you made public comment with FWS, please SHARE with us and please include the tracking number assigned to you.
While you were enjoying a quiet Thanksgiving holiday with your family, US Fish & Wildlife Service (FWS) was taking aggressive action against reptiles and other animal interests.
FWS has notified the Office of Management & Budget’s (OMB) Office of Information and Regulatory Affairs (OIRA) that it will finalize the ‘Constrictor Rule’ adding more boas and pythons as injurious species, as well as propose two additional rules that will allow FWS to more easily administer the Injurious Wildlife list of the Lacey Act, and effect greater control over the import, export and interstate transport of reptiles and many other animals. The full ramifications of these three rules will not be clear until until they are published in the Federal Register likely in early 2014.
What is clear is that FWS seeks to add more constricting snakes to the Injurious Wildlife list of the Lacey Act. At risk are: Boa constrictor, reticulated python, DeSchauensee’s anaconda, green anaconda, and Beni anaconda. This is in addition to the listing of four constricting snakes in 2012: Burmese python, northern and southern African pythons, and the yellow anaconda.
1) RIN: 1018-AV68- Title:Injurious Wildlife Evaluation; Constrictor Species From Python, Boa, and Eunectes Genera. We (FWS) are making a final determination on the listing of five species of large constrictor snakes as injurious wildlife under the Lacey Act: Reticulated python, DeSchauensee’s anaconda, green anaconda, Beni anaconda, and boa constrictor.
Further, it is also clear that FWS seeks to increase their power and streamline the process to add other species to the injurious species list, while also increasing restrictions and fees on import, export and transportation of ALL wildlife.
2) RIN: 1018-AX63- Title: Injurious Wildlife; Making Injurious Wildlife Determinations Under the Lacey Act. We (FWS) propose to revise our regulations for listing species as injurious in order to enhance the species screening process and enable more efficient and effective decisions that will help prevent the introduction and spread of injurious wildlife.
3) RIN: 1018-AZ71- Title: Importation, Exportation, and Transportation of Wildlife. We (FWS) propose to rewrite a substantial portion of our regulations for importation, exportation, and transportation of wildlife. We (FWS) will propose changes to the port structure and inspection fees.
With the apparent unwillingness or possible inability of the reptile community to file a lawsuit challenging the shaky legal standing of the original ‘Constrictor Rule’ of 2012, FWS has become emboldened to press their advantage. Burmese pythons and three other constricting snakes were added to the Lacey Act under what some think to be an “arbitrary, capricious and unlawful” process conducted by FWS. Now FWS threatens to add five more snakes, including boa constrictor and reticulated python.
2014 promises to be a critical year for many in herpetoculture. From zoos and research facilities to commercial breeders and hobbyists, TV and film to pet owners, ALL will likely be negatively impacted by proposed rule changes to the Lacey Act.
Please share this with your friends and family. Join our mailing list, follow our blog, and follow the US Herpetoculture Alliance (Herp Alliance) on Facebook for the most timely and accurate news and analysis on all issues regarding herpetoculture.
(Some people are attempting to make public comment by commenting on the Herp Alliance Blog page. This will NOT work! Comments must be emailed directly to FWS at email address with sample letter)
The “Categorical Exclusion” (CatX) proposed earlier this month by US Fish & Wildlife Service (FWS) is the single most dangerous threat ever fielded against herpetoculture! If enacted, CatX would pave the way for FWS to easily add species to the Injurious Wildlife list of the Lacey Act by waving due process under the National Environmental Policy Act (NEPA). NEPA requires due process with science, economics and social impact considered prior to listing. CatX would eliminate NEPA mandated impact studies! Please read this entire alert and take the action outlined below!
Small Business Administration Meeting:
On July 17, 2013, the US Herpetoculture Alliance led a coalition of small business stakeholders and associations in a meeting with the Small Business Administration Office of Advocacy (SBA) in Washington, DC. SBA was interested in collecting input from stakeholders regarding small business impacts of the proposed FWS CatX. This was the most important high level government meeting in several years; and likely the last prior to the CatX debate. Participants included representatives from the Association of Zoos & Aquariums (AZA), Zoologic Association of America (ZAA), US Herpetoculture Alliance, The Frog Ranch, Gourmet Rodent and Vida Preciosa International (VPI). Our coalition was very well received, and we believe SBA will come out in support of small business. PIJAC/USARK were invited, but declined to attend.
Meetings at US House and Senate:
While in Washington, DC, Herp Alliance CEO, Andrew Wyatt met with Congressman Tom McClintock (R-CA) from the US House Natural Resources Committee (HNR) and professional staff from the Senate Environmental & Public Works Committee (EPW). FWS published notice of the CatX over the 4th of July holiday weekend without directly contacting impacted stakeholders. It has taken some time to analyze the CatX and formulate an informed opinion. The current deadline for public comment is July 31st. The Herp Alliance, AZA and ZAA have all requested that FWS extend the deadline for public comment on CatX by 60 days. HNR and EPW are supportive of our requests.
On behalf of the Herp Alliance, Congressman McClintock promised to ask new Interior Secretary Sally Jewell whether she was aware of the CatX and it’s implications.
“Madam Secretary, you may be aware that FWS recently proposed a rule for Categorical Exemption from NEPA mandates regarding “Injurious Wildlife Listings” under the Lacey Act. This Committee understands well the challenges in dealing with invasive species, however, I am concerned that exempting the FWS from addressing the Environmental, Economic and Social impacts of proposed additions to the list could be extremely damaging to small business; as several of the species FWS seems to be targeting are widely traded and would have a significant economic impact. I’d like your commitment to look into this matter and get back to me before the service finalizes their rule making on this issue”. ~ Congressman Tom McClintock
The US Herpetoculture Alliance expects to have an answer from Secretary Jewell prior to the July 31st deadline for public comment.
Make Public Comment Today; Deadline July 31st!
It is of paramount importance that the herpetoculture community take CatX seriously and make comment prior to the deadline. Herp Alliance CEO Andrew Wyatt expressed his concerns regarding CatX, “I am afraid that CatX has not registered with herpers… this is the greatest threat to ownership and trade of herps in the history of herpetoculture”! CatX is a much greater threat than the python ban. FWS seeks to completely exclude themselves from the scientific and economic considerations they currently must observe. If CatX is enacted FWS can arbitrarily add any animal to the Injurious Wildlife list without due process under NEPA. Further, legal recourse under NEPA would no longer be available. Wyatt added, “Make no mistake, this is the biggest threat we have ever faced. Nothing is safe under CatX. All reptiles and amphibians are at risk! Please make public comment”.
The Herp Alliance implores you to make public comment prior to the deadline of July 31, 2013. We have developed a template covering the most pertinent talking points along with an individual request for a 60 day extension on public comment. You can also use the talking points to write your own comment. Email us at email@example.com for more detailed talking points.
***Copy and paste the following template into an email and send it to FWS. Be sure to include the subject line. Make public comment prior to July 31 deadline. Email directly to:
I am against the proposed US Fish & Wildlife “Categorical Exclusion” from NEPA mandates. This action could facilitate the arbitrary addition of animals to the injurious wildlife list of the Lacey Act; potentially threatening the entire $1.4 billion annual commerce in reptiles and amphibians. Not only would it negate due process, but it would also negate legal recourse under NEPA. Categorical Exclusion could potentially become a tool to destroy my small business. Please consider the following points:
The proposed categorical exclusion bypasses the requirement to consider economic and social impacts under NEPA.
A categorical exclusion would not allow FWS to fully consider the beneficial impacts of declining to list a species under the Lacey Act.
The proposed categorical exclusion is much broader than any of the other eight exclusions that FWS has approved under “permitting and regulatory functions”.
The FWS’s “extraordinary circumstances” exception to a categorical exclusion is unhelpful because it does not apply to actions with high economic impacts.
Additionally, the 30 day public comment period is far too short to make a fully informed comment. FWS published the proposed rule in the federal register over the holiday weekend. 30 days is not adequate to get full participation and quality comments. I am requesting that the public comment period be extended by 60 days.
The US Herpetoculture Alliance remains committed to providing the most sophisticated and effective advocacy available for herpetoculture. Others cannot match our talent, experience or high level connections. We break the news first, provide in depth analysis on the issues and support the community with the most effective advocacy strategy and tools.
Click here for FWS notice in Federal Register on CatX:NEPA-FWS
On July 9, 2013 the US Herpetoculture Alliance CEO Andrew Wyatt was contacted by Assistant Chief Counsel from the White House Small Business Administration’s Office of Advocacy (SBA). SBA is seeking input on the potential small business impact of the newly proposed Categorical Exclusion rule, where by the US Fish & Wildlife Service (FWS) seeks to avoid due process mandated under the National Environmental Policy Act(NEPA).
Consistent with their mission of protecting small business from undue governmental regulation, SBA has requested that Wyatt facilitate industry participation in gathering information that will be useful to support small business stakeholders in the rule making process. To that end, the Herp Alliance has invited stakeholders to participate in a meeting to be held next week at the Office of Advocacy in Washington DC.
The invitation list includes representatives of the Pet Industry Joint Advisory Counsel (PIJAC), FELD Entertainment, Association of Zoos & Aquariums (AZA), Zoological Association of America (ZAA) and the US Association of Reptile Keepers (USARK). Additionally, we have requested stakeholder participation from individual businesses that feel the proposed rule would negatively impact their particular small businesses.
This Categorical Exclusion from NEPA is NOT just about constrictor snakes. It could potentially effect hundreds, even thousands of species… and remember the potential for a rule adding ALL amphibians to the injurious list is still outstanding.
The US Herpetoculture Alliance is opposed to a Categorical Exclusion of NEPA mandates. An exclusion would make it easier for FWS to arbitrarily add animals important to zoos, research, education, entertainment and herpetoculture, to the Injurious Wildlife list of the Lacey Act. The SBA recognizes that Andrew Wyatt has been a central figure in the Lacey Act “injurious debate” for almost six years; and as such has enlisted his assistance. The Herp Alliance appreciates that SBA is giving us an opportunity to help small business on this important issue.
Wyatt stated that, “SBA support opposing the Constrictor Rule was enormously helpful in 2010-2011. Now we have an opportunity to garner that support once again.”
Additionally, the US Herpetoculture Alliance is requesting a 30 day extension from FWS on public comment for the proposed Categorical Exclusion rule. Currently the deadline for public comment is July 31st, but FWS published their announcement on a busy holiday weekend without notice to stakeholders. We feel it is only fair to give as many stakeholders as possible an opportunity to comment.
US Fish & Wildlife Service To Finalize Constrictor Rule-making
The US Herpetoculture Alliance has confirmed that the US Fish & Wildlife Service (FWS) has stated it’s intention to finalize the constrictor rule-making in the Summer of 2013. Known as the “Constrictor Rule”, this regulatory effort by FWS was initiated in 2008, and finalized in part in January 2012. The partially finalized rule added Burmese pythons and three other constrictor snakes to the Injurious Wildlife list of the Lacey Act. Five other constricting snakes, including Boa constrictor and reticulated python remain in regulatory limbo designated as “under consideration.” The scientific and economic argument made by FWS to list the four constrictors was widely regarded as suspect. There is no science regarding the remaining five. The Herp Alliance calls on FWS to release the five remaining constrictors from further consideration.
In April Herp Alliance CEO, Andrew Wyatt filed a request for regulatory review with the White House Office of Management and Budget based on a “regulatory uncertainty” costing American herpetoculture hundreds of millions of dollars in what amounts to a de-facto listing. The Herp Alliance requested that FWS adhere to it’s own mandate of “retrospective review” and withdraw all five species from consideration for listing. For several months Wyatt has continued to be in close contact with staff of both the Senate Environmental & Public Works Committee and the US House Committee on Natural Resources, who have independently requested briefings on this issue from FWS. At this point the agency has not determined whether they will include additional species in the finalized rule, but have stated their intention is to finalize the rule this summer. It is likely given this Administration’s history on this issue that they will pursue additional species. Herp Alliance will provide updates as FWS makes decisions in this regard.
May 22, 2013. For over twenty years, it has been illegal in this state to own a constrictor 15′ in length or longer. Today, the Illinois General Assembly failed to pass SB 2362 (the “Herptile Code”) which would have lifted the ban on constrictors over 15′ in length and eased restrictions on venomous snakes. In addition, the Herptile Code would have removed all reptiles and amphibians from the Illinois Dangerous Animals Act.
The Herptile Code is the brainchild of Scott Ballard, Heritage Biologist and Herpetologist with the Illinois Department of Natural Resources. Ballard wrote the Herptile Code with significant input and feedback from the reptile community over the past year, including Rob Carmichael, Brian Potter, Erika Chen-Walsh, and many, many others within the reptile community.
Although the Herptile Code swept through the Senate with a unanimous vote of 54 in favor, it encountered some resistance in the House. HSUS opposed the Herptile Code at both Senate and House Committee hearings and issued an action alert opposing SB 2362. In addition, multiple Illinois Republican representatives informed us that they had received emails from an individual in the pet industry raising objections to the Herptile Code. The House voted today 38 in favor and 78 opposed. The bill is now dead.
Andrew Wyatt and Erika Chen-Walsh sent 118 faxes and Michael Stevens hand delivered 298 hard copy letters written by Herp Alliance to Illinois legislators in support of the Herptile Code. Wyatt and Chen-Walsh made nearly 100 phone calls and we spent the day in Springfield, speaking directly to Republican legislators opposing SB 2362 on May 14th.
The Herptile Code was the first bill from 2013 that would have provided a tangible improvement to reptile legislation. Unfortunately, amid opposition from the powerful animal rights industry and the pet industry, the House did not carry the votes.
On April 23, 2013, Herp Alliance, with your help, passed a milestone since our inception in late December 2012: in just four months on Facebook, we received over 10,000 likes.
Founded by a small and tightly-knit group of individuals, we have tried to hit the ground running to help protect herpetoculture from an ever-encroaching animal rights industry, to help conserve reptiles and amphibians through captive propagation, to protect science and education involving these magnificent animals, to promote high quality captive breeding, and of course, to preserve the ability of individuals to keep their cherished pets.
Early in the year, we engaged Frank Vitello, of Vitello Consulting, to assist us at the federal level, and Frank has delivered in abundance with our legal strategy, outreach, and connections to help protect against additional bans on the keeping of reptiles as well as seeking closure to the Lacey Act Rule Change that went into effect in 2012.
The 2013 legislative season is not yet over. Since January, the Herp Alliance team has accomplished the following:
Herp Alliance was the first to initiate closure on the python rule to remove the 5 remaining species of constrictors from consideration under the Lacey Act.
We issued an Action Alert that has generated nearly 700 letters to President Obama urging Secretary Salazar to close the Constrictor Rule before leaving office and Herp Alliance sent our own.
We broke the news and took the lead on opposing HR 996, Representative Louise Slaughter’s proposed Invasive Fish and Wildlife Prevention Act.
Herp Alliance president, Andrew Wyatt, together with our DC consultant, Frank Vitello, visited Washington DC in March and met with Speaker John Boehner, Senator Bill Nelson’s Chief of Staff, Pete Mitchell, Senator Marco Rubio’s staff, Chairman Darrel Issa’s House Oversight Committee staff, Ranking Member David Vitter’s Senate EPW staff, Chairman Doc Hastings’ House Natural Resources Committee Staff Director Harry Burroughs, and others to raise awareness of herpetoculture’s most pressing federal concerns.
We learned of HSUS’s push to President Obama and Interior Secretary Ken Salazar to finalize the ‘Constrictor Rule’ and to add 5 additional species to the constrictor rule of the Lacey Act and we exclusively brought that news to you.
We learned that learned that Senator Bill Nelson (D-FL) would introduce his own version of the ‘Nonnative Wildlife Invasion Prevention Act’ (HR 669 from 111th Congress) in this session and brought that news to you along with the first “discussion draft” of his bill.
We broke the news on ballot initiatives in Illinois, California, New York, New Jersey, Nevada, Pennsylvania, Tennessee, Virginia, West Virginia and Connecticut and immediately issued action alerts to challenge those bills.
With over 400 letters sent to committee members in Connecticut, we engaged in that state with you until the ban on boas and Burmese pythons was killed in committee.
As a result of the incredible efforts of Jared Watts and VIIPER, outstanding ground support in Virginia and Andrew Wyatt’s involvement and influence in the Virginia Dangerous Animals Initiative, together we defeated Virginia SB 477 and HB 1242.
Along with West Virginia Reptile Watch and its leaders Joe Perdue and Greg Stephens, together with approximately 500 letters from our supporters, Herp Alliance engaged in West Virginia against SB 466 and HB 2209 and both bills died in committee without moving forward.
We engaged in Wilson County, Texas, with Jason Royer and Dave Barker, where Andrew Wyatt proposed a ‘policy solution’ that ultimately reversed ordinance 1998-1 banning constricting and venomous snakes.
We have reviewed in excess of 550 state level bills for their potential impact on herpetoculture.
In all states with open legislation, we remain actively engaged and hypervigilant.
It has been a busy first four months, but we are not tired yet. The reptile community has been sharply divided and politicized for some time. For those of you who have had the faith in us to give us your support on Facebook, on the forums and in emails, we thank you. For those of you who have contributed financially to our cause, we thank you. And for those of you who have sent letters, made phone calls and taken direct action to help fight for herpetoculture, we thank you most of all.
Andrew, Kim, Doug and I appreciate all that you have done. We are in this fight for you and with you, and we are not going away anytime soon!
On April 18, 2013 H 3985 was introduced into the South Carolina House of Representatives. H 3985 is an onerous bill that could ban the possession and trade of hundreds of species of reptiles; including constrictor snakes, venomous and crocodilians. This bill was introduced by Representatives J.E. Smith and R.L. Brown, and referred to the House Committee on Agriculture, Natural Resources and Environmental Affairs. H 3985 is a template for “Dangerous Wild Animal” (DWA) legislation that is being pushed by the Humane Society of the United States (HSUS). It is a threat to tens of thousands of animal owners in South Carolina.
If passed as written H 3985 could make it “unlawful for any person to import, possess, sell, transfer, or breed a dangerous wild animal”. The list of reptiles that would be prohibited under H 3985 are:
( i) Order Crocodylia: all species of alligators, crocodiles, caimans, gharials;
(ii) Order Squamata:
(A) Family Atractaspidae: all species, such as mole vipers;
(C) Family Colubridae: boomslangs (Dispholidus typus), twig snakes (Genus Thelotornis);
(D) Family Elapidae: all species, such as cobras, mambas, and coral snakes;
(E) Family Hydrophiidae: all species, such as sea snakes;
(F) Family Viperidae: all species, such as rattlesnakes, pit vipers, and puff adders; and
(iii) All species listed under the Federal Endangered Species Act (50 C.F.R. 17.11) as threatened or endangered are considered dangerous wild animals.
In addition, there is a “grandfather clause” that would allow current owners to keep their animals with requisite documentation to prove ownership prior to July 1, 2013.
The Herp Alliance shares the same federal consultant (Vitello Consulting) with the Zoological Association of America (ZAA) and The Institute of Greatly Endangered and Rare Species (TIGERS). In addition, we have reached out to Feld Entertainment in order to work with multiple stakeholders to address concerns with H 3985.
H 3985 is straight out of the HSUS playbook. They have coined the term, “Dangerous Wild Animal” to define their legislation and strike fear into the hearts of legislators and the public. The US Herpetoculture Alliance is committed to fighting this H 3985 “tooth and nail”.
“Georgia and the Carolinas are my home. South Carolina has always been a bastion of personal liberty. There is NO justification for the kind of draconian legislation that has been introduced.” ~ Andrew Wyatt, CEO US Herpetoculture Alliance.
Stand by for the coming action alert to empower you to take ACTION to OPPOSE H3985.
“The US Herpetoculture Alliance Protects the Future of Herpetoculture and Promotes Conservation Through Captive Breeding”
After engaging Chairman Miley’s office at the WV House Judiciary Committee, and Chairman Craig’s office at WV House Natural Resources Committee the US Herpetoculture Alliance has been informed that it is “highly unlikely” that SB 466 and HB 2209 will move forward. West Virginia herpetoculturists can breathe a sigh of relief, both of these bills will be dead tomorrow. They will both hit deadlines for reporting out of committee on April 11, 2013.
HB 2209 was “dead on arrival.” Once introduced into the WV House of Delegates, it never found any traction once it was referred to committee. However, SB 466 was a much different story and gave us quite a scare.
SB 466 is a broad sweeping, ambiguous ban on exotic animals. “Dangerous Wild Animals” are defined as “mammals, birds, reptiles, amphibians and aquatic life, including hybrids, that are dangerous to humans, other animals and the environment due to their inherent nature.” Wildlife, agricultural animals and domestic animals already defined by West Virginia statute are exempted. However, SB 466 vests authority to a Dangerous Wild Animal Board (the “Board”) to list dangerous wild animals pursuant to administrative rule making authority.
SB 466 was sponsored by Senate Majority Whip William Laird. Senator Laird is also Chairman of the Senate Natural Resources Committee to which SB 466 was referred. SB 466 was reported favorably out of Natural Resources on March 6th, the same day it was introduced and referred to committee. Subsequently SB 466 was reported out of the Senate Finance Committee without notice nor testimony on April 2nd where it then moved to the Senate floor and passed by a vote of 32-1 on April 3rd.
SB 466 then crossed over to the House of Delegates and was referred to the House Judiciary and Finance Committees. This was where the Herp Alliance was able to more fully engage the bill. The Herp Alliance CEO, Andrew Wyatt, engaged in a number of conversations with Chairman Wiley’s office at House Judiciary. Wyatt had strong grass roots support from Joe Perdue, Greg Stephens and dozens of Herp Alliance supporters from West Virginia Reptile Watch, a WV watchdog group of businessmen and herp enthusiasts. Wyatt was told that SB 466 had not been assigned to an attorney at House Judiciary, and didn’t likely have enough momentum to run prior to the April 11 deadline. The only way SB 466 could move forward is to be reported out of the Judiciary committee, and then be reported out of the Finance committee by tomorrow. That is NOT likely to happen.
The Herp Alliance would like to thank West Virginia Reptile Watch and it’s leaders Joe Perdue and Greg Stephens for a job well done! Tomorrow will be a great new day in West Virginia!