The new ivory regulations also extend to interstate and intrastate
moves within the U.S.A.  As the regulations are written now, it seems
it will be legal to own a piano with ivory keytops, but not legal to
sell one unless you can prove that it's over 100 years old, the keytops
are original to that piano, and you have a CITES certificate stating
this.  However, there is a temporary hold on enforcement (see below).
If you don't read this entire message, please read at least the last
three paragraphs.

In the last year, a Piano Technicians Guild (PTG) member in the Chicago
area spent months trying to get a Boesendorfer grand certified with its
original keytops but failed because Fish & Wildlife said there was no
way to prove that they were original.  Consequently, she replaced them
with plastic.

Piano Technicians Guild officials and about 30 other organizations have
signed a letter of concern that was sent to the House Ways and Means
Chair.  They've also been in dialogue with the two largest pipe organ
technician organizations to consider lobbying strategies since the PTG
and pipe organ groups have similar interests.  The PTG plans to publish
an article on the subject in its May Journal.  The board of AMICA is
also aware of this and will be kept informed.

I sent a list of specific questions to the PTG, who included them in
their communication with Fish & Wildlife.  These include things like
"How does someone prove ownership of a piano that is being moved to
a repair shop but not sold," "Will it be legal to give a piano to
someone in another state," and "What is a repair shop supposed to do
with ivories removed from an old uncertified piano when replacing them
with plastic?"

The PTG president also told me this:

 "The intent of the language was not to make criminals out of piano
  owners, so they have placed a temporary hold on enforcement of the
  new rules which were scheduled to take effect in June.  The purpose
  of the temporary hold is to come up with a set of rules specifically
  for keyboard instruments.  There will be a publication of a proposed
  set of rules at which time there is a window for public comment on
  the rules to potentially amend them.  I am committed to making those
  rules public to our PTG membership as well as publicizing the dates
  for the commentary period so our members can weigh in with their
  opinions to the correct public officials who will be deciding the
  ultimate outcome of the issue."

It might be a good idea to wait until representatives of the
organizations who have signed the letter of concern learn something
definitive before acting as individuals.  This might prevent a lot of
hearsay from getting into circulation before actual rulings are made
on exemptions, enforcement, etc.

Also, it will be wise to refrain from circulating inflammatory,
politically-charged statements against the regulations, because their
fundamental purpose -- preventing more harm to living elephants -- is
honorable.  The question is whether destroying old ivory artifacts will
reduce or increase demand for illegal poaching.  The answer remains to
be seen.

Here's another thought for all to consider: from now on, when
discussing ivory in a piano, use the term "ivory keytops" rather than
"ivory keys".  If enforcement does take place, we don't need to have
poorly-informed Fish & Wildlife agents destroying whole keyboards or
pianos because they didn't know the keys are made of wood with only
a thin layer of ivory on top, which can be removed without destroying
a whole instrument.

Art Reblitz - 40-year RPT member of PTG
Colorado Springs, Colorado