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.
Please post questions and comments below!