This Unlawful Underground Regulation was Masterminded by the executive director of the California Fish and Game Commission - Sonke Mastrup and the director of the California Department of Fish and Wildlife - Charlton H. Bonham, and was undertaken Solely to Discriminate Against and to Extort Unwarranted Funds from Wildlife Facilities Statewide.

    After the last utterly disgraced Fish and Game Commissioner Dan Richards, a former Department Game Warden was removed for Sport - Trophy Hunting of Mountain Lions you would hope that the Commission would have learnt its lesson regarding the appointment of former Department personnel. Apparently not. Yet again, another Department of Fish and Wildlife director Sonke Mastrup was subsequently appointed as the executive director of the Commission. That appointment continues to demonstrate a willful, arbitrary, and undeniable conflict of interest as the Commission is intended to be the oversight committee of the Department and must remain completely independent and not become embroiled in the agendas, unlawful conduct, and cronyism of the Department. Notwithstanding the fact that almost all of the California Department of Fish and Wildlife Game Wardens are PROLIFIC Sport - Trophy Hunters . . .  

    Many of the Wildlife Facilities now being irreparably damaged offer Wildlife Protection Services and Provide Lifetime Homes for Wildlife in Need at no cost whatsoever to the State of California. " New " Permitting Requirements now Mandate among other things, that :                             

( 1 ) Animals, including Lions, Tigers, Leopards, etc., Endure Inhumane and Risky Anesthesia Procedures for the Sole Purpose of installing microchips, as opposed to waiting until a Medical Procedure which would Require Anesthesia is needed, at which time a microchip could be humanely installed,                                                                                                    

( 2 ) Wildlife Rescue Shelters are Prohibited from Rescuing Wildlife in Need from other States and relocating them here to safe " Lifetime Homes ",

( 3 ) Skyrocketing Fees including fees for additional inspections of Wildlife Facilities which have never Possessed Detrimental Species, and

( 4 ) those inspections are done by inexperienced Department of Fish and Wildlife Game Wardens, as opposed to licensed, experienced veterinarians.

    Further, despite the questionable Public Safety and Animal Welfare Records of AZA accredited zoos and aquariums, and the hundreds of millions of dollars which those facilities rake in annually, all of their facilities statewide were given a Waiver of ALL Specified Permit Requirements, meaning No Required Microchips in their Endangered Species Animals, Unlimited, Permitted Interstate Transit of Wildlife, and No Required Fees for Inspections of their Non Detrimental Species, which is literally almost every animal they exhibit. 

    Moreover, despite the fact that Waivers of those Specified Permit Requirements are available in regulatory codes for Non AZA Wildlife Facilities, specifically those in " Good Standing " which maintain Federal Licensing and Inspections, as well as Animal Control Licensing and Inspections, and additional Veterinarian Care and Inspections, both the Commission and the Department have Willfully Engaged in Malicious, Unlawful Underground Regulation which Systematically Denies ALL such Waiver Applications, despite the Inherent Merit of those Applications. 

    None of the affected Wildlife Facilities objected to additional inspections, they merely applied for the waiver of fees for those inspections, just like the one which all of the AZA accredited zoos and aquariums were afforded, and they detailed the dangers of anesthesia, and the unarguable and inherent need to be permitted to rescue Wildlife in Need from appalling conditions in Roadside and Backyard Zoos which may be located out of state. 

    Wildlife Facilities were denied even the most basic Due Process Rights. Many qualifying facilities submitted a waiver request to the Department, all of which were systematically denied. Those facilities then submitted an appeal to the Commission. The Commission then sent those appeals out to their cronies for an arbitration - mediation hearing which was done behind closed doors, and where neither the petitioner nor their legal counsel were even permitted to appear on their own behalf. Those findings which to date have been against each and every petitioner were then submitted to the Commission for adoption. The Commission then met behind closed doors in an executive session where once again, neither the petitioner nor their legal counsel were permitted to be present. The Commission then systematically denied each and every appeal, ultimately forcing either the closure of the facility and confiscation and destruction of the animals there, or the petitioner has been forced into complying with that unlawful underground regulation despite the substantial and unwarranted hardship and burden, or they have been forced into expensive and overwhelming litigation in the courts.

    Despite the recent court ruling which severely admonished the Department and its director for that unlawful underground regulation, ( which included awarding attorney fees and costs ) it continues to this day, while they continue their legal defense on taxpayer dollars, approximately $500,000.00 and counting, and with no end in sight . . .  

    As a result, the damage done to the Animals and those Wildlife Facilities Statewide is Unwarranted and Irreparable. Accordingly, both the executive director of the Fish and Game Commission - Sonke Mastrup, and the director of the Department of Fish and Wildlife - Charlton H. Bonham have willfully failed to uphold the Public Integrity and Professional Standards required of their Public Office, and as such, they Must Be Removed From Public Office, and Be Held Accountable to the Fullest Extent Of The Law.