liverock
RC Sponsor
Thanks to the wonderful cooperation we have in our ELECTED government officials....
USFWS no longer Inspecting/Clearing any Live Wildlife or Wildlife Product Shipments
During Overtime Hours on Weekdays/Weekend/Federal Holidays
Notify Congressional Delegations Now
The US Fish and Wildlife Service notified importers/exporters on March 11, 2013 that
"Effective immediately, the Service will not inspect or clear any wildlife import or export during overtime hours on weekdays, weekends, or Federal holidays.
We urge the wildlife import/export trade to adjust the timing of shipments accordingly to prevent the loss of live or perishable wildlife/wildlife products."
The justification for the suspension of a service funded by user fees is "sequestration." See USFWS Notice: http://www.fws.gov/le/publicbulletin/pb031113-sequestration-impacts.pdf
PIJAC urges concerned people to immediately contact their Congressional delegations to alert them of the negative impacts of the Fish and Wildlife Service's decision that it will not inspect or clear ANY wildlife shipments (live animals or wildlife products) "during overtime hours on weekdays, weekends, or Federal holidays." This decision is reportedly resulting from budget cuts related to sequestration despite the fact these services involve "user fees" and is a revenue profit center that clearly covers the cost of the program.
Steps:
"¢ PIJAC recommends that people contact not only the Washington, DC offices of their Senators and Representatives, but also their district offices.
"¢ Clearly explain how the USFWS decision impacts you and your industry
"¢ Be courteous and calm
"¢ Request the staff person have the Senator or Representative contact the Department of Interior and ask for an explanation as to why they cancelled a fee-for-service program/profit center and request reversal of the USFWS decision so American businesses are not adversely impacted
"¢ Follow up with a letter or email explaining your concerns and respectfully request they keep you informed of progress
"¢ Please keep PIJAC advised of any responses your receive
"¢ Please send PIJAC copies of your written comments and any written responses you receive
"¢ If any questions email marshall@pijac.org or call Marshall Meyers at 1-202-256-6726
"¢ Forward this information to anyone willing to speak up
"¢ Encourage employees, friends, competitors, neighbors, etc. to call their Congressional representatives
Talking points
"¢ Inspection of imports/exports of live wildlife and wildlife products is a Federal requirement. Inspections normally performed by the US Fish and Wildlife Service under a program funded by user fees that include special fees to compensate the Service for "overtime." Attached is fee schedule showing that minimum overtime fee is $105 per hour for weekdays with a 2-hour minimum. This is in addition to clearance fees of $186 0r $279 depending on permits.
"¢ It is somewhat ironic that the Service has chosen to eliminate a significant portion of a profit center which generates substantial annual income.
"¢ Majority of international flights arrive/depart after hours during weekdays or are on Saturdays and Sundays.
"¢ Large volumes of aquatic organisms as well as other live animal shipments are routinely imported after hours or on weekends. In a number of situations, such imports are only on weekends due to airline space availability and long-estabished practices that have ensured best humane handling.
"¢ If weekend inspections stopped, several large importers have reported they are likely going to be forced to suspend operations or go out of business. The ability to restructure one's operations to ship live animals on non-existent airline flights leaves no alternative than to consider alternate less humane modes of transport such as sea transport!
"¢ If a shipment arrives after hours due to conditions beyond the control of an airline (e.g. Traffic congestion, weather) or the shipper, live animal shipments will be left unattended for extended periods of time until an inspector reports for duty.
"¢ The airlines will not be able to restructure their schedules to fit within USFWS timeframes.
"¢ Forcing live animal shipments to be transported via circuitous routings, multiple carriers, significantly increasing transit time, and subjecting the animals to additional stress is hardly in the best interests of the animals
"¢ Over the years, the Service and Customs have collaborated to allow conditional releases when USFWS inspectors not available so why no longer available?
"¢ Shipper requests to have Customs clear shipments under Section 14.54 (see below) when Fish and Wildlife Service officers are unavailable has been denied even though this practice is a long standing practice. A Customs clearance does not replace a USFWS inspection but can be handled in way that animals are removed to an importer's facility to be held until they receive a "post-clearance inspection" official clearance by USFWS to sell, transfer or otherwise change custody. Ask why this process could not be used, especially for live animal shipments to minimize the likelihood of loss.
"¢ Other types of information you may want to have to answer their questions:
o Port(s) normally used
o Percentage of shipments requiring USFWS O/T charges
o Estimate amount you paid 2012 for overall USFWS user fees (do not include USDA fees) and provide separately amount paid for overtime services
o Explanation of how the suspension of service adversely impacts or is likely to impact the health and welfare of the animals as well as your business
o Note issues involved if have to arrange for less desirable multi-stop transport to attempt to meet the USFWS inspection window
"¢ Emphasize that import/export inspection program is a revenue/profit center operated on a user-fee basis and there was no need to scuttle it under the guise of "sequestration"
"¢ Recommend that the inspection program be reinstated immediately and state that neither sequestration nor imposition of a hiring freeze justifies suspension of this important service
Contact Information for Senators and Representatives (Washington and District offices):
http://www.contactingthecongress.org/
Pertinent regulation on how wildlife shipments may be handled when USFWS inspectors are not available:
§ 14.54 Unavailability of Service officers.
(a) Designated ports. All wildlife arriving at a designated port must be cleared by a Service officer prior to
Customs clearance and release. When importers or their agents expect live or perishable shipments of wildlife
or wildlife products or request inspection at the time of arrival, they must notify the Service at least 48 hours
prior to the estimated time of arrival. However, where a Service officer is not available within a reasonable
time, Customs Officers may clear live or perishable wildlife subject to post-clearance inspection and
investigation by the Service.
(b) Border and special ports. Wildlife lawfully imported at Canadian or Mexican border ports under § 14.16, or into
Alaska, Puerto Rico, or the Virgin Islands, under § 14.19, may, if a Service officer is not available within a reasonable
time, be cleared by Customs officers, subject to post-clearance inspectionand investigation by the Service.
Richard TBS
www.tbsaltwater.com
USFWS no longer Inspecting/Clearing any Live Wildlife or Wildlife Product Shipments
During Overtime Hours on Weekdays/Weekend/Federal Holidays
Notify Congressional Delegations Now
The US Fish and Wildlife Service notified importers/exporters on March 11, 2013 that
"Effective immediately, the Service will not inspect or clear any wildlife import or export during overtime hours on weekdays, weekends, or Federal holidays.
We urge the wildlife import/export trade to adjust the timing of shipments accordingly to prevent the loss of live or perishable wildlife/wildlife products."
The justification for the suspension of a service funded by user fees is "sequestration." See USFWS Notice: http://www.fws.gov/le/publicbulletin/pb031113-sequestration-impacts.pdf
PIJAC urges concerned people to immediately contact their Congressional delegations to alert them of the negative impacts of the Fish and Wildlife Service's decision that it will not inspect or clear ANY wildlife shipments (live animals or wildlife products) "during overtime hours on weekdays, weekends, or Federal holidays." This decision is reportedly resulting from budget cuts related to sequestration despite the fact these services involve "user fees" and is a revenue profit center that clearly covers the cost of the program.
Steps:
"¢ PIJAC recommends that people contact not only the Washington, DC offices of their Senators and Representatives, but also their district offices.
"¢ Clearly explain how the USFWS decision impacts you and your industry
"¢ Be courteous and calm
"¢ Request the staff person have the Senator or Representative contact the Department of Interior and ask for an explanation as to why they cancelled a fee-for-service program/profit center and request reversal of the USFWS decision so American businesses are not adversely impacted
"¢ Follow up with a letter or email explaining your concerns and respectfully request they keep you informed of progress
"¢ Please keep PIJAC advised of any responses your receive
"¢ Please send PIJAC copies of your written comments and any written responses you receive
"¢ If any questions email marshall@pijac.org or call Marshall Meyers at 1-202-256-6726
"¢ Forward this information to anyone willing to speak up
"¢ Encourage employees, friends, competitors, neighbors, etc. to call their Congressional representatives
Talking points
"¢ Inspection of imports/exports of live wildlife and wildlife products is a Federal requirement. Inspections normally performed by the US Fish and Wildlife Service under a program funded by user fees that include special fees to compensate the Service for "overtime." Attached is fee schedule showing that minimum overtime fee is $105 per hour for weekdays with a 2-hour minimum. This is in addition to clearance fees of $186 0r $279 depending on permits.
"¢ It is somewhat ironic that the Service has chosen to eliminate a significant portion of a profit center which generates substantial annual income.
"¢ Majority of international flights arrive/depart after hours during weekdays or are on Saturdays and Sundays.
"¢ Large volumes of aquatic organisms as well as other live animal shipments are routinely imported after hours or on weekends. In a number of situations, such imports are only on weekends due to airline space availability and long-estabished practices that have ensured best humane handling.
"¢ If weekend inspections stopped, several large importers have reported they are likely going to be forced to suspend operations or go out of business. The ability to restructure one's operations to ship live animals on non-existent airline flights leaves no alternative than to consider alternate less humane modes of transport such as sea transport!
"¢ If a shipment arrives after hours due to conditions beyond the control of an airline (e.g. Traffic congestion, weather) or the shipper, live animal shipments will be left unattended for extended periods of time until an inspector reports for duty.
"¢ The airlines will not be able to restructure their schedules to fit within USFWS timeframes.
"¢ Forcing live animal shipments to be transported via circuitous routings, multiple carriers, significantly increasing transit time, and subjecting the animals to additional stress is hardly in the best interests of the animals
"¢ Over the years, the Service and Customs have collaborated to allow conditional releases when USFWS inspectors not available so why no longer available?
"¢ Shipper requests to have Customs clear shipments under Section 14.54 (see below) when Fish and Wildlife Service officers are unavailable has been denied even though this practice is a long standing practice. A Customs clearance does not replace a USFWS inspection but can be handled in way that animals are removed to an importer's facility to be held until they receive a "post-clearance inspection" official clearance by USFWS to sell, transfer or otherwise change custody. Ask why this process could not be used, especially for live animal shipments to minimize the likelihood of loss.
"¢ Other types of information you may want to have to answer their questions:
o Port(s) normally used
o Percentage of shipments requiring USFWS O/T charges
o Estimate amount you paid 2012 for overall USFWS user fees (do not include USDA fees) and provide separately amount paid for overtime services
o Explanation of how the suspension of service adversely impacts or is likely to impact the health and welfare of the animals as well as your business
o Note issues involved if have to arrange for less desirable multi-stop transport to attempt to meet the USFWS inspection window
"¢ Emphasize that import/export inspection program is a revenue/profit center operated on a user-fee basis and there was no need to scuttle it under the guise of "sequestration"
"¢ Recommend that the inspection program be reinstated immediately and state that neither sequestration nor imposition of a hiring freeze justifies suspension of this important service
Contact Information for Senators and Representatives (Washington and District offices):
http://www.contactingthecongress.org/
Pertinent regulation on how wildlife shipments may be handled when USFWS inspectors are not available:
§ 14.54 Unavailability of Service officers.
(a) Designated ports. All wildlife arriving at a designated port must be cleared by a Service officer prior to
Customs clearance and release. When importers or their agents expect live or perishable shipments of wildlife
or wildlife products or request inspection at the time of arrival, they must notify the Service at least 48 hours
prior to the estimated time of arrival. However, where a Service officer is not available within a reasonable
time, Customs Officers may clear live or perishable wildlife subject to post-clearance inspection and
investigation by the Service.
(b) Border and special ports. Wildlife lawfully imported at Canadian or Mexican border ports under § 14.16, or into
Alaska, Puerto Rico, or the Virgin Islands, under § 14.19, may, if a Service officer is not available within a reasonable
time, be cleared by Customs officers, subject to post-clearance inspectionand investigation by the Service.
Richard TBS
www.tbsaltwater.com
