Comment on FR Doc # 2010-23342

Part 21 MIGRATORY BIRD PERMITS Comment: The stated definitions of public institution, public museum and public zoological park in 21.3 appear to exclude a number of very established, private-non-profit, open-to-the-public, non-AZA-accredited organizations. Lake Erie Nature & Science Center and other similar organizations fall outside these stated definitions due to the following: We are not a public institution because we are privately run as opposed to “…operated by a Federal, State, tribal, or local government agency.” We are not a public museum because we are not accredited by the AAM and not a public zoological park because we are not accredited by the AZA nor can we be certified as an AZA Related Facility as AZA defines those as “not open to the public.” As a private, non-profit educational organization with a $1.2 million annual budget and a history dating back to 1945 including exhibiting and utilizing programmatic wildlife, I’m hopeful that the new regulations do not intend to reduce or limit the educational animal possession abilities of us and similar organizations. Being open to the public 358 days of the year hosting 80,000 walk-in visitors and over 80,000 class and program participants and maintaining a corps of over 100 live animals on exhibit and for use in programs, we certainly meet the rest of the definition of zoological park. While becoming accredited by AZA would solve this problem, AZA accreditation is one of the most stringent accreditations in the public institution arena. Many major US zoos have even chosen to not become accredited and for reasons non-animal related we have also not chosen to apply for this accreditation. Referring to the definitions in Part 22.3 of Eagle Permits, most of these excluded organizations would fall under the Public Scientific Society definition so adding Public Scientific Society to Section 21.3 may resolve this concern.