Recently I returned from our Nation's capital having been involved in two very important meetings.

The first was the Public Hearing for comments on Importation, Exportation, and Transportation of Wildlife; Inspection Fees, Import/Export Licenses and Import/Export License Exemptions being proposed by the U.S. Fish and Wildlife Service.

After the meeting it appears that upon publication of the Final Rule in the Federal Register there will no longer be any exemptions from Inspection Fees for personally hunted trophies. This means that approximately 30 days after publication of the final rule Hunters will be subjected to base user fees of $85 for each shipment at a Designated Port (All Coppersmith offices are in Designated Ports) with the addition of Premium Inspection Fees of $19 at any port for any species that requires a Permit (export or import) of Protected Species. Live species of any kind will also be assessed an additional Premium Inspection Fee of $19. Non-designated Ports will have higher additional fees. In order to recoup some of the past personnel cost overruns the service has indicated these user fees will escalate each year with rates published in the Notice of Proposed Rule Making (Vol. 73, No. 37 dated February 25, 2008 Pages 9972 to 9983 of the Federal Register) through 2012. Overtime inspection fees will continue to be assessed as before. These user fees will apply regardless of whether or not a physical inspection of the wildlife shipment is performed. These fees will appear on your Coppersmith invoice as separate line items from our services for filing the Fish and Wildlife entry.

The second meeting with Veterinary Services, National Center for Import and Export, yielded much better news. A Memo written by their staff published late last year on their website,http://www.aphis.usda.gov/vs/ncie/pdf/guide-imp-rum-tro.pdfwas not verified as effective at all U.S. Ports until this meeting.

This memo instructs Customs and Border Protection Agricultural Specialist (CBP/A) how to review documents and perform physical inspections of Hunting Trophies. This memo appears not to have been disseminated to all CBP/A staff.

We also learned in this meeting that it is normally CBP who is placing "Ag Holds" on shipments, often, in contravention of instructions to release by Veterinary Service personnel. The NCIE Director, Dr. Karen A. James-Preston, wants to be provided with any examples of this happening. Any delays or problems, which cannot be resolved at the Port level, should be directed to 301-734-3277. She suggested you contact either Dr. Maureen Bell or Dr. Kristen Rohde.

There still needs to be more interaction with this agency with regard to what they consider non-commercial versus commercial shipments; particularly as it refers to the number of animals being shipped and the mode of transportation on which they arrive into our country.

As you can see from the following message we were finally successful in getting submission to the Animal Products Manual Glossary the term "Dip and Pack"

Dr. Bell:

A stakeholder with expertise with hides skins and trophies, has submitted (with some editing by me) a definition to be included in the APM:

Dip and pack–Process whereby hides or skins are soaked in a salt solution containing mineral acid (for example, sulphuric acid) at a pH of 5 or lower and then dried and arranged in a container ready for shipment to a taxidermist or tannery.

As a writer of definitions for APHIS, I hereby certify that the above statement captures the meaning, the use, the function and the essence of the term 'dip and pack." Moreover the definition does not define the term by mere repetition or merely restating the word.

Respectfully submitted,

John L. Patterson
Branch Chief, Manuals Unit
Phone: (240) 529-0351
Fax: (240) 529-0397

Lastly, I have prepared the a Fact Sheet for distribution to our overseas agents in which suggestions offered by the Veterinary Services staff along with comments from John Janelli of the National Taxidermy Association, should simplify the inspection of Hunting Trophy Shipments.

If we can work with overseas taxidermist to come up with documents, which are uniform in their terminology, even the newest CBP/A Specialist at the first port of unlading should be able to release and on-forward these shipments to their final port of entry timely and at no additional cost to the international hunter.

It has taken six years to arrive at this point and we hope that the coming years will see the automation of this agency and others much quicker through I.T.D.S. (International Trade Data System).

Thank you for your attention to this message.

Carol Rutkowski