Piano World Home Page Forums Our Most Popular Forums Piano Tuner-Technicians Forum Last day to respond to FWS Ivory Restriction Regulations

Today (9/28/15) is the last day that the Fish and Wildlife Service will accept input (“comments”, criticism, suggestions for greater latitude for piano owners and technicians). Please use go to http://www.regulations.gov and put FWS-HQ-IA-2013-0091-0001 in the search window, and click on “View all documents and comments in this Docket”. You will have access to read comments, and the full text of the proposed regulations. For example, search for posts by a few piano technicians (John Ashcraft, Anne Acker, Sally Phillips, Phil Bondi) to see what others have written.

I suggest that you send your own comment, and that you consider conveying the following message (or whatever message you think will be helpful to the piano technicians and piano owners affected by these regulations):
 
As a Piano Technician, I urge FWS to increase the de minimis standard for pianos’ exemption from regulation restriction in ivory trade and transport to [an amount greater than the proposed 200 grams: at least 225 g, or up to 400 g to include keyboards restored with pre-ban ivory].

Sally Phillips wrote me on Friday, reminding me that the FWS’s plan to restrict our usage of salvaged ivory key tops is an equally disastrous aspect of these proposed regulations. Please consider mentioning how this will impact you and your customers.

Please also point out that the de minimis standard, although it may cover most pianos will be impossible to measure on a piano without removing the ivory. The de minimis weight really only applies to selling a piano with ivory keys across state lines. The de minimis standard does NOT eliminate pianos from this regulation across the board.

The equally damaging problem is that technicians working in multi state markets or who rebuild for out of state clients will not be able to replace any ivory on a piano. They will only be able to re glue an ivory that was original to the piano or use a synthetic filler.

This regulation will not allow for the replacement of an ivory from another old piano.

Please do put in your 2 cents on this with Fish and Wildlife.

'Dunno guys. Given the current regulatory bloat in the federal government, I don't hold out much hope for swaying entrenched bureaucrats, or policies instituted by said bureaucrats.

The effort seems analogous to trying to paddle a battleship with a toothpick.

Obviously, piano technicians do not have deep pockets so bribery is out of the picture. No hope for anything reasonable to come out of this.