Presenter: John Herron

Commission Agenda Item No. 7
Petition for Rulemaking
Amendment of Commercial Nongame Regulations
June 1999

I. Discussion: The department has received a petition requesting that the Commercial Nongame Permit regulations be amended to increase the possession limit for bullfrogs and exempt bullfrog hunters from permit requirements. The petitioners state that the current possession limit of 10 bullfrogs is too low and the $15 fee is too expensive.

The staff recommends that the petition be denied for the following reasons. First, the purpose of the commercial nongame regulations is to allow the department to assess the magnitude and impacts of commercial activities with respect to nongame species, and there is a known commercial traffic in frogs in this state; therefore, allowing the requested exemption would deprive the department of critical data. Second, the nongame collector’s permit allows persons to possess an unlimited number of specimens, and staff does not believe that the $15 fee places an undue hardship on the regulated community. Third, creating an exemption for non-commercial bullfrog hunters would also make enforcement more difficult, because ordinary field enforcement would be impossible and cases would have to be made by observing persons in the act of selling, which is both time-consuming and labor-intensive.

II. Recommendation: The staff recommends the Texas Parks and Wildlife Commission deny the petition.

Attachment - 1

Exhibit A - (Exhibit A available upon request)

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