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The International Association of Fish and Wildlife Agencies (lAFWA) 

 a non-profit association whose membership is comprised of the various state 

 fish and game management agencies has worked over the past several years 

 to implement and introduce legislation that would impose an excise tax on 

 all types of outdoor equipment including canoes, kayaks, paddles, and all 

 types of paddlesports equipment and clothing. 



Named "Teaming With Wildlife" the initiative being pushed by 

 lAFWA over the past several years as the current budgetary cutbacks and 

 restraints on a wide variety of wildlife projects and program at the state level 

 by assessing what the lAFWA calls a "user fee" of up to 5% of the 

 manufacturer's cost of goods on the equipment raised by outdoor recreation 

 participants. The money raised by this proposed tax would go to state fish and 

 wildlife agencies to fund a broad array of projects, projects as yet unnamed by 

 the proponents of the tax. 



The North American Paddlesports Association, the paddlesports industry 

 trade association, is opposed to the proposal for the following reasons. 



• Burdens on Small Businesses 



Since the lAFWA introduced their program several years ago, they 

 have maintained that this is a "user fee" in their literature and materials 

 circulate dot the trade and consumer. This would not be a "user fee" but a 

 true excise tax collected on a wide variety of outdoor equipment at the point 

 of manufacture. For manufacturer of paddlesports equipment, the majority of 

 which are small independently owned businesses, this tax would place a 

 significant burden on the time and resources of those businesses as they 

 attempt to comply and remain competitive in the marketplace. 



Our manufacturers often give "dating" to their retailers, allowing their 

 additional time to pay for their goods until the business season is well 

 underway. A tax collected at the time of manufacture, would have to financed 

 by the manufacturer and eventually the increased costs of carry that amount 

 on their books would be passed along to the retailer and the consumer. 



• Barriers to participation and purchasing 



In the current legislative and financial climate, a variety state, federal, 

 and local agencies are all looking for ways to increase their revenue stream. 

 Individually, these programs may be small and relatively inexpensive to 

 consumer. Combined their effect could be devastating to our industry. 



For example, the United States Coast Guard is considering the 

 implementation of a national registration program and user fee to fund a 

 variety of valuable coast Guard programs. At the same time, the Texas 



