You might be right, but the process seems entirely a** backwards. In a nutshell, an agency charged with protecting our environment has to put the onus on the general public to prove there ISN'T a problem? That's illogical. It's like asking a defendant in the courtroom to prove he didn't commit the crime.



All the USFW had to do is go online and do a few google searches to know that tropical snakes would not survive in 99% of the country. Even my 8 year old could do that. And if they couldn't do that, why not do a simple test (ie, putting live burms in outdoor enclosures to see how long they survive) before giving any credence to the request to even investigate. The whole thing is ridiculous.



For what it's worth, I did exactly what you suggested and made specific rebuttal points to the USFW. Hopefully it will mean something, but I'm not optimistic.



Thanks,

Ed







>>Could I make some suggestions on how to respond to the USFWS Notice of Inquiry? I've worked for various Fed agencies and understand a bit about how to deal with actions like this, what they can and can't use to make the decision.

>>

>>First, remind yourselves just what this action is...a request for specific information. Put your energy into this, not general ranting. Don't drop to the level of PETA and the like. The ban is not being proposed right now...they are asking whether a ban might be necessary based on numbers and costs. The questions are listed in the notice. Anything else you send can't or won't be used, so spend your time until April 30 carefully. Believe me, I've spent days pawing through public comments on various rulemakings and know what isn't going to be useful to the decision maker. Give them a general opinion and the response will be "OK, well, thanks for commenting...but nothing you said gives me any more to work with".

>>

>>They are looking for specific things upon which to base any proposed ban. We can stop this by providing them overwhelming information that a non-specific sweeping ban on constrictors just isn't warranted. Try to get answers to the listed questions in your states...talk to breeders, dealers, pet shops, etc. about what they produce, sell, etc. Support your information. Are there feral constrictors in your area? No? Yes? Are native species being decimated by feral snakes? Remind them that the impacts from invasive weeds (also classed as injurious species), feral cats and rats (no one proposed banning the interstate movement of housecats and they kill several million birds every year all over the US, including endangered ones), habitat loss are far more important to endangered species recovery than non-existent exotic constrictors. The recovey plans for every listed species describes the documented threats...make the case that exotic constrictors are not the primary threat. If you don't know, find out! Overwhelm them with information! We want to make the point that a broad brush ban isn't necessary or even effective. Other injurious species are listed and managed on a species and regional level. Snakes could be also. If FL has a problem with a specific species for whatever reason suggest that they deal with it on a specific level. If VT or MT don't have a problem and never will, a ban on exotic constrictors there just isn't warranted. Remind them that native snakes also prey on those threatened species and are already adapted to their specific climates. We can defeat this with reality, with reason, with information, not screaming and wailing about philosophies.

>>

>>Thanks for letting me comment.

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