OHI,



Thanks man for posting this one…This is a chilling reminder that the “agenda” from the environmental and conservation “commissars” that the spirit of HR-669 and S-373 is not forgotten…Looks like they've introduced a Plan B to the legislative problem...



>>3. Public Benefit/Cost Note.



>>Major Sinclair also has determined that for each of the first five years the rule as proposed is in effect:



>>(A) The public benefit anticipated as a result of enforcing or administering the rule as proposed will be the deterrent effect of the denial of license privileges for persons who have not complied with conservation law in any jurisdiction affected by the Compact.



On the basis of what? A voluntary “compact” between states to regulate INTERSTATE trade…What will they think of next?



>>(B) Under the provisions of Government Code, Chapter 2006, a state agency must prepare an economic impact statement and a regulatory flexibility analysis for a rule that may have an adverse economic effect on small businesses and micro-businesses. The department has determined that there will be no direct economic effect on small or micro-businesses or persons required to comply as a result of the proposed rule. Accordingly, the department has not prepared a regulatory flexibility analysis under Government Code, Chapter 2006.



Without preparing an “economic impact statement”, how can they determine whether this “compact” will affect small business or not? I see that they have adopted the reverse of the burden of proof here…The citizen has to prove its affect in the public comment period because the government has already made its decision…



>>(E) The department has determined that there will not be a taking of private real property, as defined by Government Code, Chapter 2007, as a result of the proposed rule.



Really? Why is this even in the equation? Unless they’ve been “networking” with USFWS regarding their lawsuit troubles in court, why would Texas even address the issue of the “taking of private real property”? The Association of Fish and Wildlife Agencies (AFWA) must have attended a USFWS “networking” seminar sponsored by a “dot-org” to share information…



>>5. Statutory Authority.



>>(4) receive information from and provide information to other member states;



Really? This new IWVC has provisions for a “network” of state agencies to share information regarding compliance with the IWVC regulation in Texas? What if your state has provisions that does not require a license if you do not “SELL” more than a certain number of animals per year? Does this mean that I’ll have to get some kind of an “out-of-state” license from Texas to ship there even if a license to sell in my state is not required? This IWVC "compact" idea sounds like something from the EU to ship between COUNTRIES!



>>(5) process nonresident violators who are residents of other member states; and



And how does Texas propose to do this? Unless my state adopts this “compact”, how is Texas going to “process” me in another state when I’m in compliance with my state laws? Unless there is some federal “string” in this equation regarding interstate trade…Ummmmmm, I wonder.



Welcome to the USSA…United Socialist States of America.



Later,

Jim.


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CSRAJim

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