Based on that, this letter is going to the Fish and Game Commission:

Date: October 29, 2024

California Fish and Game Commission
P.O. Box 944209
Sacramento, CA 94244-2090

Subject: Formal Request for Regulatory Review of 14 CCR 671 and the Classification of Domestic Ferrets

Dear Members of the California Fish and Game Commission:

I am writing to formally request that the California Fish and Game Commission (FGC) conduct a thorough and scientifically-based review of 14 CCR 671, which currently classifies domestic ferrets as a restricted species, alongside wild and detrimental animals. This request follows correspondence with the Office of Administrative Law (OAL), which has informed us that the authority to review and amend this regulation lies with the FGC. As such, I am now petitioning the Commission directly under Government Code Section 11340.6, requesting the amendment of 14 CCR 671 to remove domestic ferrets from the list of restricted species.

Background and History of Unfair Treatment

For decades, the California Fish and Game Commission has subjected ferret owners to undue and unfair treatment based on outdated and unsubstantiated claims about the nature of domestic ferrets. Despite overwhelming evidence supporting the domestic status of ferrets, the FGC continues to classify them as wild and detrimental animals, even though no scientific data has ever conclusively demonstrated that ferrets pose a threat to California's environment or public health.

We believe this long-standing regulatory stance by the FGC lacks the necessary scientific foundation and has never been justified by an open, transparent, and rigorous review. As noted in California Civil Code Section 655, domestic animals, including ferrets, should not be subject to restrictions meant for wild or harmful species unless it is clearly proven that such classification is necessary. To date, such proof has never been presented.

Legal Basis for Petition and Request for Review

Under Government Code Section 11340.6, we have the right to petition for regulatory change, and under Government Code Section 11340.7, the FGC is obligated to respond within 30 days of receiving this petition. We formally request that the Commission initiate rulemaking proceedings and thoroughly examine the inclusion of domestic ferrets in 14 CCR 671.

This examination must consider the best available science and should involve public hearings where we can present expert testimony, peer-reviewed studies, and evidence from states where ferrets are legal and pose no environmental threat.

The Fish and Game Commission must also comply with the Administrative Procedure Act (APA), which mandates transparency, public participation, and due process in regulatory matters. We demand that these standards be fully upheld as you review our petition.

Moving Forward

Given the long history of neglect and misclassification of ferrets as wild and harmful animals, I am prepared to pursue this matter to the fullest extent of the law. Should the FGC fail to adequately address our concerns or dismiss this petition without a thorough review based on facts and science, I will have no choice but to seek judicial review under Government Code Section 11350, which provides for the invalidation of regulations that lack a legal or scientific basis.

I am ready to reinitiate legal proceedings in California Superior Court, pro se, if the Commission does not act in accordance with its legal responsibilities. I am committed to challenging this issue until the FGC addresses the injustice and reclassifies domestic ferrets fairly and accurately.

Conclusion

I respectfully urge the Commission to take this matter seriously and initiate the necessary steps to remove domestic ferrets from 14 CCR 671. It is time to correct this regulatory overreach and give ferret owners in California the same rights and protections afforded to residents in the 48 states where ferrets are legal and recognized as domestic animals.

Thank you for your attention to this important matter. I look forward to your timely response and to working together toward a fair and just resolution.