Post by alex2 on May 4, 2005 23:01:25 GMT -5
Got this e-mail from CHC today:
Hi all.
As we get down to the wire here, We wanted to send out one last CHC pitch for the critical issue of keeping the Federal permit as opposed to the NAFA recommendation of eliminating it. I won't go into deep detail unless asked, but here are the bullet points that scream out to keep the FP in place...
1. States are already commenting that they cannot pick up the additional costs or workload that will be incurred when the feds turn over permitting to them. CA told us outright that they would have to discontinue a falconry
program that incurred additional costs.
2. States will not necessarily recognize other state permits
(reciprocity) for travel and field meets. CA, for example, says that they will definitely not enter into any additional reciprocity agreements, and that a Federal permit is currently required for some types of transit. This will
prevent falconers from traveling to other states. No NAFA meets, anyone?
3. Without a FP protecting our sport, there is no umbrella encouraging states to maintain a permit system. It's a divide-and-conquer situation.
4. If your state decertifies, you will no longer have the protection of a FP to allow you to move out of state. You could be stopped at the border or at the Fish and Game office with a "sorry, you have NO permit to possess
those birds. We have to confiscate them".
5. If the regs are different between states, State A is less
restrictive than State B, and you travel from your home State A to State B, if you meet the law in your state, you may be subject to action in State B, because State B is under no obligation to recognize State A's permit.
These issues and more have the potential for killing off falconry in some states. Even if it's only one state, it's too many. We feel that NAFA should have looked at these regs with a "first, do no harm" outlook. It seems to me
that they have instead decided that the majority benefit (lower annual fees and reduced paperwork) is worth the potential to lose falconry in some places. We don't agree. We are seriously considering requesting an extension
of the comment period in order to try and come up with a solution for this issue that will protect falconry in all areas.
We presented these issues to Darryl Perkins, NAFA president, the day their detailed comments came out, and he has promised to call and discuss them. That's been 2 days now with only a few left for comments. We look
forward to discussing this with him, but are not going to wait any longer.
It's critical that everyone send in comments, especially a comment requesting to keep the federal permit in place. I am willing to send in onemore piece of paper and pay a little more to ensure that falconry can be practiced anywhere in the US. I hope others do too.
Thanks for your time...
Hi all.
As we get down to the wire here, We wanted to send out one last CHC pitch for the critical issue of keeping the Federal permit as opposed to the NAFA recommendation of eliminating it. I won't go into deep detail unless asked, but here are the bullet points that scream out to keep the FP in place...
1. States are already commenting that they cannot pick up the additional costs or workload that will be incurred when the feds turn over permitting to them. CA told us outright that they would have to discontinue a falconry
program that incurred additional costs.
2. States will not necessarily recognize other state permits
(reciprocity) for travel and field meets. CA, for example, says that they will definitely not enter into any additional reciprocity agreements, and that a Federal permit is currently required for some types of transit. This will
prevent falconers from traveling to other states. No NAFA meets, anyone?
3. Without a FP protecting our sport, there is no umbrella encouraging states to maintain a permit system. It's a divide-and-conquer situation.
4. If your state decertifies, you will no longer have the protection of a FP to allow you to move out of state. You could be stopped at the border or at the Fish and Game office with a "sorry, you have NO permit to possess
those birds. We have to confiscate them".
5. If the regs are different between states, State A is less
restrictive than State B, and you travel from your home State A to State B, if you meet the law in your state, you may be subject to action in State B, because State B is under no obligation to recognize State A's permit.
These issues and more have the potential for killing off falconry in some states. Even if it's only one state, it's too many. We feel that NAFA should have looked at these regs with a "first, do no harm" outlook. It seems to me
that they have instead decided that the majority benefit (lower annual fees and reduced paperwork) is worth the potential to lose falconry in some places. We don't agree. We are seriously considering requesting an extension
of the comment period in order to try and come up with a solution for this issue that will protect falconry in all areas.
We presented these issues to Darryl Perkins, NAFA president, the day their detailed comments came out, and he has promised to call and discuss them. That's been 2 days now with only a few left for comments. We look
forward to discussing this with him, but are not going to wait any longer.
It's critical that everyone send in comments, especially a comment requesting to keep the federal permit in place. I am willing to send in onemore piece of paper and pay a little more to ensure that falconry can be practiced anywhere in the US. I hope others do too.
Thanks for your time...