[NHCOLL-L:2660] Re: USFWS and 3-177 forms

[Doug Yanega]

>We file most of our 3-177s electronically now ("eDecs"), and we've 
>had several instances recently where inspectors at our local office 
>(Chicago) required us to bring the packages to their office for 
>physical inspection before they will clear the 3-177.

This seems very odd, given that - according to the regs in the last 
revision (which I have a copy of) - you have a 180 day grace period 
to file a 3-177 form. It does NOT have to accompany a shipment. Just 
ship your package, and file at your convenience. Since when did the 
FWS start pretending the grace period doesn't exist? If Mike 
Carpenter were here (I think he's on permit-l) he could probably tell 
us for certain, but I've certainly not heard of them rescinding the 
grace period (i.e., if a more recent revision has been snuck in below 
the radar in the last few years).

Heck, I'll just crosspost this to permit-l, and see what it turns up. 
I strongly suspect you're dealing with people who don't understand 
how form 3-177 works.
-- 

Doug Yanega        Dept. of Entomology         Entomology Research Museum
Univ. of California - Riverside, Riverside, CA 92521-0314
phone: (951) 827-4315 (standard disclaimer: opinions are mine, not UCR's)
              http://cache.ucr.edu/~heraty/yanega.html
   "There are some enterprises in which a careful disorderliness
         is the true method" - Herman Melville, Moby Dick, Chap. 82