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Official Caudata.org Comment on the Federal Register

John

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This is what I've posted on regulations.gov in response to the new USFWS rule banning interstate transport of newts and salamanders. Please make your comment within the next 24 hours as the deadline is tomorrow. Feel free to plagiarize the Caudata.org comment but please do not copy it word for word to any great extent. I am aware there is more that could be said but I chose to limit the talking points to the most important ones. I've also attached our survey data summary - thank you to everyone who participated in the survey and to everyone who submitted a comment to USFWS.

"Please find 3 PDF documents attached to this parent comment.

The first document contains the comment from Caudata.org.

The second document contains a transcript of Dr. Frank Pasmans' comments on assertions made in the rule by USFWS - Dr. Pasmans is one of the authors of several of the B.sal papers cited in the rule by USFWS and we post this full transcript with his permission.

The third document contains a summary of the data gathered by Caudata.org in our survey of US collections and interstate transport of newts and salamanders and small businesses. We gathered this data to inform decision making because in formulating this rule the USFWS drew conclusions about interstate transport and trade based on little-to-no data from the citizens and small businesses involved."
 

Attachments

  • Caudata.org B.sal. Comment.pdf
    124.5 KB · Views: 545
  • Dr. Frank Pasmans Email on Rule FWS-HQ-FAC-2015-0005.pdf
    42.3 KB · Views: 543
  • Caudata.org B.sal. Comment Survey Summary.pdf
    522.3 KB · Views: 509
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