My Statement #1 to FWS during the comment period, ending Sept 28,2015
These rule changes will stop the production of and destroy the value of an American National Heritage ART- Scrimshaw. By disallowing legal and legitimate trade and requiring documentation that never existed and is impossible to produce, pre-ban ivory collectors will not be able to continue to collect and thereby preserve this truly American art form. The exceptions in the Proposed Rule are useless and do not adequately allow legal and legitimate commerce as directed in Executive Order 13648 on Combating Wildlife Trafficking in July 2013. FWS set retroactive documentation requirements too high and this undermines all of the exceptions by placing an unachievable burden on legal ivory owners. The agency is so obscure with the document requirements that even if an owner or business has some documentation about an ivory item, we cannot be certain whether documentation is adequate.

Your list of arrests and convictions prove there is not a sizable amount of ivory entering this country illegally. Most ivory entering the States illegally is brought in by people who are just ignorant of the laws, not “smugglers”. We have adequate laws on the books that allow for the confiscation of illegal ivory as it enters the country. These changes will waste resources, distract from actual poachers and smugglers, and unfairly persecute people who abided by international trade bans that were already in place. Along with creating bad policy, FWS shows misuse of data that violates the Information Quality Act.

The US has a closed ivory market, banned from importing ivory for over 25 years. Our price on raw ivory is 10-15% of the Asian market. So how will these rule changes help the elephant? It won’t. This law will only hurt American taxpayers.
Where are the financial studies? Your estimate of the financial impact is sadly understated. You are affecting businesses all over the United States from antiques to organ repair, musicians to scrimshaw artisans, investment speculators to professional pool players. Putting some small businesses out of business and severely hurting others. Small businesses are the backbone of this country.
The FWS certification in the proposed rule that it would not have a significant economic effect on a substantial number of small entities as defined under the Regulatory Flexibility Act is false, as is their finding under theSmall Business Regulatory Enforcement Fairness Act that there is not a disproportionate impact for small or large businesses.

All this evidence works against FWS and these changes making them illogical, illegal and unnecessary. So again I demand FWS withdraw the proposed rule change entirely .
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