The U.S. Fish and Wildlife Service needs to offer a substantive justification for basing a major element of Rule 4(d) on an outmoded definition of what is or is not an antique.

• Using the economic reasoning behind the Smoot-Hawley Tariff Act of 1930 hardly seems relevant to the need to protect and preserve artifacts for American society that are culturally significant, historically noteworthy, and artistically important.
• Using an antiquated and inadequate definition is contrary to the commitment of the Service to adhere to the underlying spirit of the Office of Management and Budget’s goal of getting the Nation’s regulatory system “to promote …………….. READ FULL ARTICLE