CBW-CITES Question

[Toons1978]

Ooooo kay so instead of trying to figure out loopholes, I submitted my permit application & $$ last week and received the email today saying FWS received my app, heres a case #, now be patient while we review/process it(30-90 day turn time). From this point what difficulties, if any, have any of you had in the processing of your permits? The wait time in my mind doesn't count as a difficulty; as an active duty fella, how to wait is learned from day 1! Also feel free to message me if you think this is a discussion that is best not to clog up the top of a forum.

 

[8james8]

I didn't experience any issues with my permit. Mine took just under 9 months for approval. I began following up more often by phone and email at the 6 month mark. I had lots of experience with other species that I leaned on and I showed pictures of my property and staging areas for outside enclosures and a hybrid indoor outdoor set up for inclement weather and transition. My indoor set ups I provided pictures and a complete description.

I received no questions. My following up professionally and politely with a decent amount of persistence paid off in the end.

I know others that were denied because of inexperience with the species or their ability to house outdoors was questioned.

There are a few others that can give better direct examples of denials. It also helped that I had reputable breeders listed on my application.

 

[Toons1978]

Taking your advice James, I've ben politely following up, mostly by email. About a month ago the biologist in charge of my application emailed some follow-up questions to which I responded the same day. I gave her a call a few days later to confirm receipt of my email and make sure there were no further questions on her part. I had filled in the gaps in information they wanted so ready for the register and I should expect to see it in 30-60 days. My app did not make the 21 June public review publication. I contacted her yesterday and she said she hopes to have mine and a few others that she is working on the July publication. So with any luck I'll have my permit approved in time this year before I'm unable to have tortoises shipped; I have a very short period when temps allow for it up here in Alaska. From early April until late August/early September is the time frame when I am able to do more than window shop. In addition to James, thank you everyone else in this thread with useful advice.

 

[8james8]

That's awesome. It seems if you hit the public review then it's usually a formality at that point.

The polite and professional persistent contact really makes a difference. The whole quiet mouths don't get fed thing really seems to ring true.

Please keep us posted. I would love to see you get it.

Btw: they just email you a copy within a few days of your public review completing. They do not mail a paper copy. The electronic version is more than suitable.

 

[coastal]

I doubt they will approve a permit in Alaska for Radiata. This one will be interesting to watch, my guess you will receive a denial letter for climate and outdoor concerns when adults. Unless you plan to move in a few years to a warmer climate or some reason you won't live in Alaska much longer after active duty. May the odds be in your favor wonderful animals none the less.

 

[deadheadvet]

I have seen the PRT listed, then the comment period comes, and the supervisor brings the hammer down and denies the application for arbitrary reasons. Sometimes it is out of the hands of the biologist. The supervisor is a real SOB. Stay on top of the application. That way they know you are politely hassling them.

 

[Sterant]

I have had lengthy conversations with biologists that review applications and they both said that once their review is complete and the application is passed on to the Branch Chief (The "Supervisor" Evan mentions above), not only do they not have any control over things, but they are not allowed to discuss it as "the file is no longer on my desk". However, the biologist can relay messages to the Branch Chief. I have called him , without exaggeration, 50 times in a 6 month period (leaving a voicemail every time) and he didn't answer the phone or return any of my messages - not once. The biologists will answer the phone occasionally and they say they will relay messages to the Branch Chief, which I believe they do.

 

[8james8]

With that much follow up if the branch chief seems to be the reason (if denied) then you could appeal on that basis.

This is exactly why I did not apply while I was on active duty. The threat of moving overseas again and my high deployment rate would likely have prevented the approval.

 

[deadheadvet]

The appeal is likely going to go nowhere. You are not allowed to appeal with any new information. It would trigger a new application and a new fee. You can only appeal the application and any reasons for the denial in that application.Unfortunately every denial is slightly different. It is always some arbitrary finding. Most of the time, the denial is because you do not have any experience with the species. It's a catch 22, how do you get experience if you can't get the species. Total horseshit. You would have to find someone in your state that has them in order to get experience with them prior to submitting the application. Having extensive experience with other tortoises helps a lot. The rarer the tortoise the better chance of getting approved. Any schmuck can breed Russians or Sulcatas and get offspring. Try getting offspring from Pancake Tortoises or Star tortoises or some of the rare box turtles. Then that carries weight in the application.

 

[8james8]

My star and boxie experience is what I leaned on

 

[Toons1978]

I doubt they will approve a permit in Alaska for Radiata...climate and outdoor concerns when adults.

One of the follow up questions they had did revolve around this. They were more concerned about extended loss of power. My neighborhood was designed with all power and comm lines under ground, not a single telephone pole or wires to get iced over and cause power loss. That doesn't prevent incidents at substations though; three years ago a stinking wolverine chewed into some wires at a power substation and when it hit the hot ones he caught on fire, knocked-out half the city's power and the fire spread and wrecked that power station. It was then I realized even in my well-planned neighborhood, a back-up generator is needed. All around my neighborhood the experienced residents had them running and it sounded like a lawn-mowing contest. My chosen genny can power my fridge, giant moose/caribou/salmon meat freezer, more than double my current tortoise capacity, and have left over juice to charge phones, macbooks, power the router, and a few other niceties.

I have seen the PRT listed, then the comment period comes, and the supervisor brings the hammer down and denies the application for arbitrary reasons.

Sooo you're saying I shouldn't put that deposit down on a shiny, brand new tortoise just yet eh? While I'm a primarily positive person, life has def taught me that lesson I learned in first grade but didn't quite understand fully; "don't count your chickens before they hatch."

Having extensive experience with other tortoises helps a lot. The rarer the tortoise the better chance of getting approved. Try getting offspring from Pancake Tortoises or Star tortoises or some of the rare box turtles. Then that carries weight in the application.

That was another line of questions they had. Until last Saturday when he died I had a common boa that I raised since Oct of 1992. After him my longest held reptile is a redfoot that I’ve had for about a decade. I've never been a person to get a critter then want to trade it off for the next best thing 6 mos later. When I lived in FL 11 years ago I had a pair of redfoots I raised that eventual laid multiple times a year over multiple years; 9 yrs before that I was in PA(where I grew up) I had Eastern Boxies, spotteds, eastern painted turtles and a few other species breeding for me. Their question was more or less, that’s nice but what have you done lately? I explained that my Active Duty career got busy for a while there and I spent more time in other countries than home until 4-5 yrs ago. I’ve got a patient wife that is ok feeding huge snakes and needy tortoises when I can’t be around. Then I brought them up to speed on my current herd.

My indie-stars hump most soaking days and nearly every time I give them fake rain with my sprayer. I’ve not seen a positive connection in person but she has gained close to 98 grams in the last 4 weeks (10g was a normal week pre intro). She’s been hanging out in odd spots of her enclosure and pacing at times not associated with food sooo fingers crossed. The eastern boxies are a year, maybe two off from being ready to make babies. My Pancakes were super interested when first introduced but that waned pretty quickly. I may move the male soon and see how they do when he returns from his “deployment” as it were. Always did the trick for the two of the mammals in this house ;-) .

I explained all of that and a few other questions about a month ago and she said she was good with it just had to go to the next level, her supervisor then ready for publishing. In my discussion a few days ago she said it was ready for pub so I took that as supv approved? Again, fingers crossed, I’ll hope for the best and if I get denied, maybe I’ll try my hand at raising Burmese stars. I'm sure my very patient wife wont mind me hijacking her wine fridge for a month every so often.

 

[zovick]

In what state was your current driver's license issued? If it's from one of the lower 48, you could possibly buy a Radiated Tortoise from another resident of that state even if you now live in AK. If your driver's license is from AK, I don't think you will find any Radiated breeders or owners, at least none of which I am aware.

How about your wife's driver's license? It could be another option.

 

[8james8]

Bill brings up a good point i had not thought of. It wouldn't necessarily have to be your drivers license.

 

[Toons1978]

In what state was your current driver's license issued?

My D/L and technical residency is Texas. AK like most states require spouses to get new D/Ls so hers is an AK ID. I see radiated sales from TX every so often but as discussed earlier in the thread, the law becomes murky when it comes to shipping them over state lines even when buyer & seller are residents of the same state.
I've read the law interpreted as being designed to restrict interstate commerce, period. If the LE division of FWS felt the same way, they have a lot more funding to dispute it in court than I do. Again instead of loopholes I'm going for the most proper means. Once I retire (I'm eligible in 13 mos)I have 30 or 60 days to swap my D/L over.

 

[zovick]

The fact that the animals are shipped from one person to the other is not something which is reported to USFWS. All that would be shown on the annual report to USFWS is a sale from a person at one TX address to a person at another TX address. The only thing needed in the report by the seller would be the buyer's legal TX address.

Heck, hypothetically you could buy one from another resident of TX who is also without a permit, and that sale would not even be reported to USFWS. Since neither party has a permit, there would be no requirement to report the activity to anyone. The only requirement to report the movement of the animals between parties comes from holding the Federal permit. (Note: some states also require permits for endangered species. I am speaking here only of the Federal requirement in states with no restrictions on Endangered Species).

However, I do understand the reluctance to take any chances on that residency issue. I am just pointing out what is actually shown on the reports to USFWS and that the manner in which the animals get from one person to the other is not part of the equation.

 

[tglazie]

This entire thread shows exactly why H.R. 2603 needs to be signed into law. All of this bureaucratic nonsense seems arbitrary and entirely unnecessary.

T.G.