Subject: No on HR669
Dear Congressman(or woman)/Representative,

Please Oppose "HR669".

It is a fundamentally flawed Bill written by a radical environmentalist group
that seeks to end the ownership and trade of all non-native animals.

There is not a shred of scientific evidence to justify the destruction of
an animal Industry that leads the world in producing and exporting high
quality captive bred animals.

With the stroke of a pen, thousands of small American family businesses
would be bankrupted overnight.

With no quantifiable benefits, what could be the justification to destroy
a viable sector of the American economy in a time of hardship?

What will the additional drain on taxpayer dollars be to grow USFWS at
unprecedented levels, in order to destroy American small business?

These are not the "To big to fail" corporate titans, but small family businesses
with their entire net worth wrapped up in their Reptile breeding projects and
ancillary supporting businesses.

A 40 billion dollar a year industry would be wiped out by HR669.
Thousands of American families would suffer, losing everything.

• Trade in Reptiles and ancillary businesses alone is estimated to be
a 3 billion dollar a year industry.
• More than 9 million Reptiles are exported from the US annually.
• More than 11 million Reptiles are kept as pets in the US.
That means 1 in 25 households have 1 or more animals or fish.
• The US accounts for 82% of the worldwide trade in Reptiles alone.
• More than 500,000 Americans would be negatively impacted by HR669.
Thousands of small family businesses would be destroyed.
• There are approximately 4 million boas & pythons, as well as more than
7 million geckos, lizards turtles & other Reptiles in captivity in the US today.
• The United States Association of Reptile Keepers Opposes HR669.
Nonnative species in the pet trade encompass virtually every bird, reptile, amphibian,
fish and a number of mammals (e.g., hamsters, gerbils, guinea pigs, ferrets) commonly
kept as pets.

It is immaterial under HR 669 that the
• Vast majority of these nonnative species in the pet trade have been in the
United States in large numbers for decades, some for hundreds of years, and
have not proven to be an environmental problem.
• Numerous species are raised in the United States for many purposes:
pets, recreational fishing and hunting, food, etc.
• Only a small number of species kept as pets have caused environmental problems,
and this has generally been on a very localized basis (i.e. southern Florida, Hawaii).
• Most states have exercised their authority to regulate problem species within their
own borders through a mixture of management regimes ranging from permit
systems to bans.

The HR 669 listing criteria mandates proving a negative – that no harm has or is
likely to occur within whole of the United States.

• The “risk assessment” process is too limited in scope and application and should
instead be a broader “risk analysis” that also takes into consideration socio-economic
factors and mitigation (management) measures that might be utilized by the federal
and state agencies.
• The approach taken in HR 669 will adversely impact trade and other activities
involving nonnative species without utilizing a scientifically valid approach –
even in the limited instances in which sufficient data are available on the biology
and range of species, it will be virtually impossible to prove that they could not
establish and spread in some portion of the US.

Thus, it will be nearly impossible to get species on the “Approved List”
unless they are so widespread in the country already.

• The degree of uncertainty that will result by applying the “as if” criteria
will result in virtually everyspecies ending up on the list for which there is
insufficient information to make a decision DESPITE THE FACT that most
of these species have been in trade, recreational use, farming, etc., for
decades with only a small percentage of species being problematic, and
then in localized situations.
• A one size fits all species assessment process is not plausible –
what may be harmful in Hawaiian waters would not be harmful in Kansas,
or the deserts of Arizona, or Texas.
• HR 669 overly simplifies the complexity of the issue; bans all species
unless they can get on an Approved List; the criteria for the Approved List
are not realistic; the lists are biased towards those entities that can (4) afford
to engage in the process – undoubtedly the Service will be paralyzed by activist
animal rights and protectionist environmental organizations petitioning for species
to be unapproved.
• The Service does not have the capacity to implement the provisions given limited
staff, money, and unrealistic timeliness.
• The unintended consequences of a sloppy bill could actually be to facilitate the
mass release of animals, and/or their mass euthanasia.
• HR 669 does not take into consideration the socio-economic complexity of the issue.

Stakeholders dependent upon access to non-native species include diverse interests:
pet industry, sports fishing, federal/state hatcheries, agriculture, biomedical research,
entertainment, hunting, food aquaculture.

Currently, thousands of non-natives species are both imported and exported,
as well as captive raised (in some instances farmed on ranched) within the United States.

While most of these species are never intended for release into natural environments,
some of these species (e.g. oysters, trout, bass, deer, game birds) are managed by
government and private entities throughout the US.

• HR 669 calls for a risk assessment when, in fact, a risk analysis process is warranted.
A risk assessment only considers biological indices related to potential invasiveness,
while a risk analysis considers both these, as well as socio-economic factors, including
potential management options.

A risk analysis can enable strategic decisions to be made, such as enabling certain
species to continue in trade/transport if the risks of invasion could be sufficiently
management (e.g. HR 669 treats the entire United States as if it is a single ecosystem
and ignores the commonly accepted definition of invasive species that applies to a
specific ecosystem, not the political boundaries of country.

• Setting criteria in statute removes flexibility that could be achieved through rule making,
since a “one-size fits-all” process is not appropriate for all taxonomic groups, regions of the
country, proposed usage of the species, etc.
• Deadlines are unrealistic.
While we recognize the rationale for placing time frames on the Service,
deadlines cause lawsuits; deadlines mandate action for unfunded mandates;
two years is unrealistic to conduct an assessment (even a rough screen) of
literally thousands of species (1) imported, (2) raised in US for local markets
as well as exports, and (3) imported as well as raised in US.

• The inclusion of animals owned prior to prohibition of importation (Section 2(f))
is major departure from current prohibitions under Lacey Act. HR 669 would allow
possession of “an animal” if the owner could prove that it was legally owned pre-launch
of assessment. There is no indication as to what it takes to prove legality.

Nor is it clear that one would know when an assessment of a particular species had been launched.

• Assuming that more than a handful of nonnative species end up on an Approved List,
enforcement of a list of approved species that have been in trade for decades will be
more difficult than enforcing a smaller "Unapproved List".

It is well established that only a small percentage of the species in trade
have been shown to be “invasive.” The ornamental aquarium industry, for example,
deals with more than 2,500 species of freshwater and marine fish.

A handful of species have been found to be a problem in southern Florida,
but not elsewhere in the US; some found to be a problem in Hawaii,
are not a problem in Kansas.

• Promulgation of regulations implementing the HR 669 process will be complex
and it is doubtful that it can be achieved within prescribed time frame, especially
if the Service is to simultaneously conduct thousands of assessments on species
already in trade.

Please Oppose HR669!

The costs to American Families would be enormous.

The benefits are both questionable and non quantifiable.

NO ON HR669.

Please take the time to actually Read this again!!!

There will be a problem with Pets, if this bill passes.

Not only will it effect our pets, but the economy as well.

People have to make our supplies, and if the bill passes,
it can create a domino effect with the employment of breeders,
and the people who make our supplies!

Not only will that cause many to Lose their jobs, but it will
limit those of who rely on out of state suppliers for feed supplies,
enclosures, heating equipment, etc., needed for our pets.

Sincerely,

Ms. Margaret *****
**my address**

P.S.
I wouldn’t want to see you lose Your pets...
Would you really like to see me lose mine?