PUBLIC SUBMISSION | As of: March 16, 2009 Tracking No. 803d3647 Comments Due: April 25, 2008 |
Docket: FWS-R9-LE-2008-0024
Importation, Exportation, and Transportation of Wildlife; Inspection Fees, Import/Export Licenses, and Import/Export License Exemptions
Comment On: FWS-R9-LE-2008-0024-0001
Importation, Exportation, and Transportation of Wildlife; Inspection Fees, Import/Export Licenses, and Import/Export License Exemptions
Document: FWS-R9-LE-2008-0024-0008
Comment on FR Doc # E8-03330
Peru, IL, 61354
Government Agency Type: FederalUSFW, ( Federal eRulemaking portal )
Please reconsider. What you are doing is punishing the legal importers.
1. Two years ago, you increased the License FEE by 100%. Such an increase
has not even resulted in-so-much-as any emails or letters to us regarding
changes, laws, FEE increases, or answers to questions put forth. What did that
FEE increase result in? Can I call for assistance (several Inspectors) and get the
same legal/enforcement answers to my questions? No. But I MUST somehow
correctly abide by and follow such wishy-washy laws/rules.
2. Now you intend to increase the Inspection FEEs by 60% this year. I have
been given fewer options for legal inspection, yet I am going to pay more if you
implement the $30 increase to $85 per package--going to $93 per package in
2012. If a package I have sent to me even marked "Attention USFW" somehow
gets to my door, I can't even call my old Port to get it cleared--they told me 'no
more'. What I am supposed to do next depends on the particular inspector I
speak with and legal inspection is next-to-impossible as I was told by several
USFW people, including one Regional Inspector Supvsr.
3. Don't force us collectors who collect and do not sell to be Commercial. Have a
dealer FEE and a Collector FEE or charge by the number of specimens. If $ is
needed, fine violators more heavily. Your Yoshi case, as I read about it, didn't
even recover the costs (via your fines) of arresting him in the multi-year sting
operation. Nail the violators and let us legal collectors go about importing without
so many obstacles and additional FEEs.
4. Your recent Port issues are still another obstacle and high-cost item for us.
While I understand your wish to get the packages stopped before they get to us,
having us hire brokers to handle the packages (via the Memphis HUB for Fed Ex
for example) for still another FEE is getting a bit much. One can, as I was
informed, more easily and cheaply deal with firearms while dead insects is treated
as though it is some sort of drug trade-like thing.
I still believe that addressing our packges to some particular USFW Port for
inspection would solve the problems. All the legal packages would be inspected
uniformly and inconsistency would be lessened. The legal importer of record
would be the one paying for the service and after the package was stopped and
inspected, it would be sent along to the particular importer of record.
I also offered a ways back to assist in making a spot for your website to spell out
the laws and rules that currently 'drown' a person in all the pages of legal-eagle
material that now exists.
5. What is this Premium FEE all about? If I import legal specimens that happen
to be CITES II, why should I have to pay another $93 per package by 2012? I'm
not talking about live stuff here, just dead papered butterflies. If I import a package
containing just one common CITES II specimen of say a $10 value, I'll have to pay
another $93 by 2012!!! Raising the Inspection FEE ...and... creating a new
additional Premium FEE is likely to be the 'straw' that 'breaks the back/bank', and
in so doing, will likely push legal importers into cessation while encouraging or
widening the illegal importations that happen all over the place. Your Inspectors
have the papers from the CITES country doing the exporting to go by. Put effort
into policing/enforcing illegal importations and skip the new Arlington facility type
of endeavors and FEE inceases which FAR exceed the rate of inflation.
6. When you buy specimens in a sting operation (like Yoshi's), fine the
perpetrator, sell off the material and generate revenue. Make the fines for illegal
importations so high that it deters many and generates much $ from those who
elect to sneak stuff in. You should have no trouble finding 'sneakers'.
7. Your mission statement: "The mission of the U.S. Fish and Wildlife Service is
working with others to conserve, protect and enhance fish, wildlife, plants and their
habitats for the continuing benefit of the American people. We are both a leader
and trusted partner in fish and wildlife conservation, known for our scientific
excellence, stewardship of lands and natural resources, dedicated professionals
and commitment to public service." is nicely written, but where does "scientific
excellence" stand when a legitimate hobby/science of insect studies is detered in
so many ways? How does "commitment to public service" fit into the new
rules/FEEs that punish the legal importers? My public service is reduced, my
costs to import dead insects is increased greatly again and this is
called "commitment to public service"? With a few exceptions like Barry Davis of
TN and few others, how is 'trusted' factored into your mission statement? Take a
question like what I've repeatly submitted to the USFW---what countries are off
limits for importations? I received conflicting answers and even was treated as
though I was some sort of thug at one point. Like an illegal importer is going to
call you people for assitance. Is 'trusted' a correct word for when inquires to the
USFW leave one wondering ----what's up or what trouble am I in now?
8. Your intention to enforce the rules/laws is important and a good thing. Please
just don't kill the legal insect collectors in the process. It is not my/our fault that
importation problems exist. Try making the USFW a user-friendly operation and
not intimidating or cost-killing to do it right. I read that several requests from
InsectNet.com have asked for Forum assiatance from the USFW---none done.
Search the site and you'll see that I have posted many times trying to help others
import legally. I have documentation for every insect I've imported or even bought
here in the USA and I would please ask you to allow people like me to continue to
persue this hobby without stifling obstacles and costs. Would having my
Congressman/Senator speak on my behalf be more likely to generate reasonable
results? If so, then that should not be too daunting a task. I realize I am a mere
one citizen, but I'm led to believe that our public officials can/and do serve in this
capacity.
Lastly, some of my friends think I'm crazy for contacting you as they feel as
though trouble will result. I did elect to contact you and basically be honest and
speak out with the rights to speak freely that this country so deeply cherishes. I
did so as to hopefully get you to reconsider. I proposed solutions to the problems
and if I can help you further in any way from a collector's (legal importer's)
viewpoint, please let me know.
Thank you for your time.
Respectfully, Bill Garthe
p.s. I'm officially requesting that my entire mesage be read out loud to the
members of this meeting coming up when public input is considered.