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USDA to close "loophole" that allows licensees in ban states

Exotic legal issues, bans, laws, regulations, Animal Rights discussions etc.

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USDA to close "loophole" that allows licensees in ban states

Postby TamanduaGirl » Fri Oct 20, 2017 1:56 pm

We need comments on this AR are having people copy paste comments in favor : https://www.regulations.gov/docket?D=APHIS-2017-0062

More info: https://www.regulations.gov/document?D= ... -0062-0001

They will make people reapply every 3-5 years with new initial inspections.

but that also slipped into the middle of this a blurb that they plan to close "a loophole in the current regulations that allows individuals and businesses, although they do not operate as bona fide exhibitors, to become licensed as such in order to circumvent State laws restricting ownership of exotic and wild animals to AWA-licensed exhibitors" There's no details on what this means exactly but could uproot and kill a lot of animals.
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Re: USDA to close "loophole" that allows licensees in ban states

Postby TurkRoach » Sat Oct 21, 2017 3:29 am

Do I need to be an US resident in order to take action?
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Re: USDA to close "loophole" that allows licensees in ban states

Postby TurkRoach » Sat Oct 21, 2017 3:31 am

Nevermind. I found out that I dont need to be a US resident. Howeve what should I say?

Edit: I did write my comment. Sadly it is a bit ill-prepared
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Re: USDA to close "loophole" that allows licensees in ban states

Postby TamanduaGirl » Sat Oct 21, 2017 1:50 pm

There is a form letter that has been made up: https://wildzoonews.com/2017/10/14/30-s ... r-23-2017/

I also happen to be against the main premise of the plan. We are already inspected regularly to see if we comply so making us reapply every few years just creates redundancy. So I started with that then I addressed the other part they added. I didn't remember exactly what I said but similar to above, that they needed to specify how they are planning to do this because all options I can think of have major draw backs. AZA only allowed as "boneafide" creates a private monopoly and could be a supreme court case in the making and minimums needed to apply could leave some not needing a license that they might prefer be licensed like a bear or lion owner who stays just under their limits.

The government would be creating a monopoly if they only licensed AZA because AZA is a company not a government office. This would leave USDA open to being sued due to anti trust laws and those kinds of cases usually wind up in the supreme court. A possible long legal battle should make them think twice about doing that. I think that's the least likely thing for them to do but it's possible since a lot of states do it(though, as said here, is not really legal, we've just had no one with the money to fight sue over it yet). It would obviously help to know what they plan instead of guessing but they didn't go about this right and just slipped a blurb in the middle of this plan about making people reapply.

You are actually allowed to comment more than once if you have more to say.
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Re: USDA to close "loophole" that allows licensees in ban states

Postby TurkRoach » Sat Oct 21, 2017 2:39 pm

Well... I would make another comment by posting the form letter, but that would contradict the argument I brought up by saying that the people for this regulation are also posting the came comments therefore they don't know what they are doing.
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Re: USDA to close "loophole" that allows licensees in ban states

Postby TamanduaGirl » Sat Oct 21, 2017 11:33 pm

And the media is against us on this: http://www.wsbtv.com/video?videoId=6261 ... ersion=1.0

The spin on this is BS. Facilities do and have lost their licenses for major and or repeat problems.
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Re: USDA to close "loophole" that allows licensees in ban states

Postby Peacefulward » Sun Oct 22, 2017 1:29 am

I swear, if this becomes official.... :chair:
5 Dogs, 2 cats, 2 leopard geckos, 1 guinea pig, 1 axolotl, and a coatimundi currently in my family. :)

Exotic "wishlist": red fox, arctic fox, gray fox, bat eared fox, fennec fox, mink, muntjac deer, owl (any species).
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Re: USDA to close "loophole" that allows licensees in ban states

Postby Juska » Mon Oct 23, 2017 2:30 pm

Left a comment.
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Re: USDA to close "loophole" that allows licensees in ban states

Postby Ash » Mon Oct 23, 2017 5:31 pm

Commented. This would hurt me considerably since I don't exhibit very often. Usually only a few times a month.
3 red fox, 4 iguanas, nile monitor, BW tegu, sailfin dragon, leachie gecko, 6 snakes, 2 salamanders, tarantula

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