“The US Herpetoculure Alliance has just received word from Interior Secretary Sally Jewell that we will receive the extension on “Public Comment” that we requested!” ~ Herp Alliance CEO Andrew Wyatt
The US Herpetoculture Alliance broke the news regarding the unprecedented and devastating impact the proposed “Categorical Exclusion” (CatX) could have on the herpetoculture community. There is no doubt that CatX is potentially the gravest threat herpetoculture has ever faced. It could remove all meaningful due process from adding animals to the Injurious Wildlife list of the Lacey Act; allowing US Fish & Wildlife Service to arbitrarily add animals in mass. DON”T LET THIS HAPPEN!
Two weeks ago Herp Alliance CEO, Andrew Wyatt, led a delegation to Washington, DC. Together with our counterparts at the Association of Zoos & Aquariums (AZA) and the Zoological Association of America (ZAA), we made our case to the Small Business Administration (SBA).
We received letters of support from the Committee Chairs of the US House Natural Resources Committee (HNR) and the Ranking Member of the Senate Environmental & Public Works Committee (EPW). Additionally, Congressman Tom McClintock pledged his support in getting answers from the Secretary of Interior.
The Senate EPW asked for a 90 day extension on public comment. The HNR asked that the CatX be completely withdrawn. We will likely not get any answers from FWS in the next few days. Stay tuned for updates.
PLEASE DO YOUR PART! The Herp Alliance has been working hard for you, now you must take action on the most important issue in the history of herpetoculture! SEND AN EMAIL TO FWS WITH YOUR PUBLIC COMMENT!
Send an Email to FWS!
***Copy and paste the following template into an email and send it to FWS (making a comment in the comment section of our blog page is NOT making “public comment” to FWS). Be sure to include the subject line. Make public comment prior to July 31 deadline. Email FWS directly:
Email Address: firstname.lastname@example.org
Subject Line: Categorical Exclusion; FWS–HQ–FHC–2013–N044
As a member of the herpetoculture community I am against the proposed US Fish & Wildlife “Categorical Exclusion” from NEPA mandates and I would like to support Senate EPW Ranking Member Vitter’s request for a 90 day extension on the public comment period.
This type of Categorical Exclusion is too far reaching and without precedent. It 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.
Click here to read Senator Vitter’s request for 90 day extension on CatX: 7.24.2013 CatX Comment Extension- Vitter
Click here to read HNR request to withdrawal CatX: PDF_Letter_to_Director_Dan_Ashe_on_Categorical_Exclusion
Click here to read Herp Alliance detailed CatX talking points: USHERP CatX Talking Points 2013