August 29, 2017
Mr. Chris Blankenship
Alabama Department of Conservation and Natural Resources
64 North Union Street
Montgomery, Alabama 36130
Dear Commissioner Blankenship:
As a deer farmer in Alabama, I would like to express my concerns with proposed rule 220-2-.138, related to Licensed Game Breeders.
The proposed rule is vague and leaves broad latitude for application up to the discretion of a future Commissioner whose position on deer farming is impossible to predict. As a small business owner, I would like to see more clarity of the rules under which I am supposed to operate.
Mandating that all deer farmers in Alabama utilize an online database to record information that is already required to be submitted to the Department is overly burdensome and seems like an effort to place the Department’s administrative function on the backs of Alabama deer farmers.
The 30-day tagging requirement contained within the proposed rule is difficult to achieve in practice and could place an undue stress on the animal. Additionally, representatives of the Alabama Deer Association were told this was not going to be included in the proposed rule by the previous Commissioner.
I encourage you to consider the negative impact this proposed rule will have on Alabama deer farmers before moving forward.