I don't think that I can add much to what PIJAC recommends below, other than to say that we are working hard to have some data here

over the weekend to help fill in the blanks. Some of the information regarding state laws has been posted here in the forums this week and may also be located in the Reptile Law Resource Center, but we plan on having data available for each states laws, numbers of pets stores that sell reptiles & supplies, numbers of vendors on kingsnake.com and what animals and products they sell.



In the meantime I recommend that everyone review the information below as it not only is a useful tool for responding to this request, but may be utilized for responding to other requests at the federal, state, and local levels.



I do recommend that even though the PIJAC suggestions do not mention dry goods, that the economic information regarding dry goods, caging, food, and other supplies and equipment utilized in maintaining these animals be included. If you manufacture cages, produce feeder items, or sell any other goods associated with keeping boas and pythons please make sure to include that data in your response.



Please note: Due to formatting issues you may have problems following the recommendations outlined below. If you have difficulty following the text you can read the original .pdf document released by PIJAC at kingsnake.com/AdviceforResponse.pdf





ADVICE FOR RESPONDING TO THE NOTICE OF INQUIRY ON PYTHON, BOA, AND

EUNECTES GENERA

APPROACH

Establish rapport and credibility. Rapport needs to be in place so that the agency reviewer wants to

hear what you have to say. Credibility encourages them to take what you say seriously.



* Lay your submission out in a business letter format.

* Make the letter your own. Avoid duplicating what other people have written. Duplication

gives the appearance of a pressure campaign and/or laziness (i.e. lack of concern for the

issue). You can draw factual information from others, but package it in a way that is uniquely

your own. Your individual voice matters.

* Limit the submission to 1-3 pages. Keep in mind that the agency staff will likely have to

review over 1000 submissions. You want them to be able to process your message quickly.

* Strategically organize the letter so that the reviewer can easily find the main points (PIJAC

provides a suggested outline below). Use bullets to "mark out" key information rather than

burying it in long paragraphs.

* Use polite language throughout the letter.

* Present the information from the perspective of being "helpful" rather than "defensive.

* Refer to the federal register notice as a "Notice of Inquiry." It is NOT a proposed rule or a

ban and if you refer to it as such you will lose credibility.

* Stick to the facts and avoid being overly emotional.

* Spell check your letter and/or have someone proof read it.



CONTENT (The following can be used as your letter outline)

Be clear, concise, and accurate. Whenever possible, back your statements up by referencing credible

literature (author’s name, publication title, date), websites (URL), and other resources. When you

respond, please indicate if the figures you provide represent actual numbers, approximations, or

averages.



* Open the letter with a polite address: "Dear Ms. Williams"

* State why you are writing: ‘I am writing in response to the Notice of Inquiry entitled,

"Injurious Wildlife Species; Review of Information Concerning Constrictor Snakes From

Python, Boa, and Eunectes genera," dated 31 January 2008.’

* Establish your credentials. Indicate relevant academic degrees, business

operations/occupation, professional memberships/affiliations (e.g., PIJAC membership),

publications, and/or snake keeping experience. (Limit to one paragraph)

* To the best of your ability, respond to one or more of the questions listed in the Notice on

Inquiry (One paragraph per question recommended):

* What regulations does your State have pertaining to use, transport, or production of

Python, Boa and Eunectes genera? [Note: If the States already have effective

regulatory and/or non-regulatory in place, the U.S. Fish and Wildlife Service

(USFWS) is less likely to perceive a need for Federal regulation].

* How many species in the Python, Boa and Eunectes genera are currently in

production for wholesale or retail sale, and in how many and which States?

* How many businesses sell Python, Boa and Eunectes species?

* How many businesses breed Python, Boa and Eunectes species?

* What are the annual sales for Python, Boa and Eunectes species? [Note: If you

provided confidential economic data to PIJAC, note this here.]

* Please provide the number of Python, Boa and Eunectes species, if any, permitted

within each State.

* What would it cost to eradicate Python, Boa and Eunectes individuals or populations,

or similar species, if found?

* What are the costs of implementing propagation, recovery, and restoration programs

for native species that are affected by Python, Boa and Eunectes species, or similar

snake species?

* What State-listed species would be impacted by the introduction of Python, Boa and

Eunectes species?

* What species have been impacted, and how, by Python, Boa and Eunectes species?

[Note: This is one of the most important questions for evaluating whether or not a

species is "injurious." Points to consider making include:

[LI] To the best of your knowledge, only two species in these three genera (Python

molurus bivitattus and Boa constrictor) have established reproductive populations

in the United States, both in southern Florida

[LI] The state of Florida, relevant federal agencies, and stakeholders are already

working to understand the dynamics of these populations, limit their impact, and

prevent future introductions into the environment;

[LI] The establishment of both of these populations was likely aided by unusual

circumstances (e.g., hurricane and/or intentional establishment by an individual),

and there is no evidence to indicate that large-scale, repeated releases by or

escapes from snake keepers are responsible.

* The Everglades is a subtropical, highly modified environment with low human

population density which offers a rather unique opportunity for the establishment

of some non-native species.

* At this time, there are insufficient data available for evaluation of the potential

benefits (e.g., as prey for native wildlife and predators of invasive species),

impacts (e.g., as predators of endangered species), or spread of Python molurus

bivitattus and Boa constrictor.

* There is a decline in the number of P.m.bivitattus being imported and propagated

in the U.S. and thus the risk of this species being introduced into the environment is diminishing.]

* Provide information on projects/programs that you are involved with that limit the potential

for Python, Boa and Eunectes species to:

* Escape or be purposefully released into the environment,

* Establish reproducing populations in the environment,

* Spread over a wide geographic area, and

* Cause harm to native species, humans, or the economy.

Examples include HabitattitudeTM (www.pijac.org), "amnesty programs" (i.e. programs in which

people can surrender unwanted pets without consequence), and your facility’s containment

processes (including during transport).

* Conclude your letter by indicating that you:

* Appreciate the opportunity to respond to the Notice of Inquiry;

* Hope the USFWS will make a science-based evaluation through a transparent process

that fully considers the costs and benefits of potential policy decisions to all relevant

stakeholders; and

* Will continue to follow the process and engage in it as necessary.

* Sign off formally, "Sincerely, X"



SEND TO

[LI]Submit comments via Internet: http://www.regulations.gov Follow instructions for submitting

comments.

[LI]US Mail or hand-delivery should be addressed as follows:

Public Comments Processing: Attn: RIN-1018-AV68

Division of Policy and Directives Management

U.S. Fish and Wildlife Service

4401 North Fairfax Drive, Suite 222

Arlington, VA 22203

Edited on April 17, 2008 at 16:02:38 by jeffb.

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