In the first place, I must applaud the clarity-oriented approach of this
rulemaking proposal, particularly the amendments to the import/export license
application. Every provision appears primarily oriented toward making
regulations easier for import/export businesses to understand and follow. I
must also commend the idea of indexing fees to inflation, and condemn any future
increases in fees beyond those mandated by the index; why hasn't this been done
before? It would effectively defuse complaints from importers/exporters, while
providing the FWS with the revenue it needs to support inspection programs.
A few specific questions/issues I have:
Instead of removing circuses from the list of license-exempt entities, why not
simply remove all exemptions and go purely from the set definition of commercial
import/export?
Regarding the inspection fee exemption for individuals carrying less than 100
furs or hides, what is to stop unscrupulous businesses from moving their
shipments in a broken up fashion with individuals in order to get around license
fees?
Comment on FR Doc # E8-03330
This is comment on Proposed Rule
Importation, Exportation, and Transportation of Wildlife; Inspection Fees, Import/Export Licenses, and Import/Export License Exemptions
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