Posted by:
OHI
at Sat Oct 3 02:22:46 2009 [ Email Message ] [ Show All Posts by OHI ]
Thanks Jim.
I wanted to comment on something, you wrote:
>>(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…
TPWD did an EIS like report for the "White and Black List" and they determined no impact on micro-businesses. I disagree. I analyized commercial herp data (and other herp data: range, fecundity and population density) for TX, for my MS thesis, and the design of the "White and Black List" turned out to be highly flawed. I should have a final paper of my work out by spring of next year (hope to publish down the road). Also an EIS was NOT done for the road ban that I am aware of. I mentioned previously (many times) that the road ban would negatively affect small herp business and it most certainly has. Also, all the new TX regs have hurt Herp Shows in the state. I know several folks who quit doing TX shows because of all the hoops and expense. Also venomous at Daytona was nixed because of compliance issues with FWC. We have commercial arguements and we should use them.
Welkerii
[ Hide Replies ]
|
RE: TX reg goes after out-of-state herpers - OHI, Sat Oct 3 02:22:46 2009