Wonderful response... thank you for taking the time to comment on the notice.

---

Dear Ms. Williams,

I am writing in response to the Notice of Inquiry released on January 31, 2008, entitled, “Injurious Wildlife Species: Review of Information Concerning Constrictor Snakes from Python, Boa, and Eunectes genera.”

As of this writing, I have been studying and caring for reptiles for the last five years. My experience and areas of interest include many species in the Python and Boa genera. In addition, I am a member of PIJAC, and a hobby breeder of pythons in the genus Morelia.

In my home state of Ohio, there are no statewide regulations for the possession or production of Python, Boa, or Eunectes genera. However, transport into the state is governed by Chapter 901:1-17-12 of the Ohio Administrative Code, “Importation and Health of Non-Domestic Animals” (http://codes.ohio.gov/oac/901%3A1-17-12), which sets out the following requirements for animals imported into the state:

• Animal must be accompanied by a state-issued permit of entry, and a certificate of veterinary inspection from the place of origin;
• Animal must be free of evidence of any contagious or infectious diseases or parasites harmful to humans or animals;
• Documentation may be required to prove the legality of ownership in the place of origin;
• Importation must be in compliance with all existing federal rules and regulations.

In Ohio, a potential introduction of Python, Boa, or Eunectes species would not cause a major impact on the State-listed native species; this is due to the large seasonal temperature shifts that result in very cold winters which Python, Boa, and Eunectes are incapable of tolerating. In a study of average temperatures across four major Ohio cities (Cleveland in the Northeast, Columbus in Central Ohio, Dayton in the Southwest, and Toledo in the Northwest), the following observations were noted:

• Average winter temperature (in Fahrenheit) for the three coldest months of the year (December, January, and February) was 31.2 degrees in Columbus; 28.4 degrees in Cleveland; 29.2 degrees in Dayton; and 26.6 degrees in Toledo (http://www.rssweather.com/climate/Ohio/Columbus and related documents).

In all cases, the average temperature remained below freezing for the duration of the winter. Such sustained low temperatures would easily kill any emerging populations of Python, Boa, or Eunectes; if an animal was somehow able to survive, its weakened state would not allow it to successfully produce offspring. Climate is a critical factor in the reproduction of reptiles, especially tropical and subtropical groups such as Python, Boa, and Eunectes. According to Dr. John Rossi, D.V.M., M.A.,

• “Improper temperatures (too hot or too cold) for too long, or the proper temperature for too short a time, are well-known causes of infertility in snakes of both sexes … temperature, humidity, barometric pressure, and time of day may be critical in determining whether or not mating will occur” (Rossi and Rossi. A User-Friendly Home Medical Reference Manual: How to Identify Disease, Preventing Disease through Proper Care, and Guidelines for Treatment. The Herpetocultural Library, 1996.)

To the best of my knowledge, only two species listed in the proposal have established viable populations in the United States; these species are Python molarus bivittatus and Boa constrictor. Both of these populations are restricted to southern Florida, which offers a unique environment for these species to thrive. Subtropical temperatures and humidity, coupled with the low human population density in the Everglades, created an ideal situation for the establishment of these species which is not likely to be reproduced elsewhere in the country.

In addition, the state of Florida, working with federal agencies and stakeholders, is already working to study these populations and limit their impact on the native environment. In 2007, Florida passed a law which established a permit system for Python m. bivittatus and five other invasive species. This law also requires owners of these animals to implant a transmittable microchip for identification.

Many responsible herpetologists are involved in programs to limit the potential of these species to escape, be released into the environment, or cause harm to humans or native species. Education of the public is key; this is something I am personally passionate about, and I use my animals to teach about reptile anatomy, care, and responsible ownership whenever I have an opportunity. I am also a staunch supporter of PIJAC’s “Habitattitude” campaign, and fully endorse the mindset laid out by their program (see http://pijac.org/i4a/pages/index.cfm?pageid=377). These beliefs are reflected in the design of my reptile housing, which minimizes the chance for accidental escapes. Each enclosure was custom-built for proper snake containment by a dedicated reptile housing company. There are no gaps or open spaces for the animal to escape, and each unit is securely bolted together and finished with ¼” tempered glass doors which can be fitted with keyed locks. When transporting my animals, they are carried in a mesh snake bag contained within a securely-locked plastic bin. Proper containment and security are of paramount importance to responsible herpetologists.

I provided confidential economic data to PIJAC via their survey; please refer to their report for thorough information regarding the annual sales of Python, Boa, and Eunectes species in Ohio and across the United States.

Thank you for allowing me the opportunity to respond to the Notice of Inquiry. It is my sincere hope that the United States Fish and Wildlife Service will make a fair, unbiased evaluation of the evidence based on science and fact, while fully considering the costs and benefits of potential regulations to the herpetocultural industry. I will continue to personally monitor the progress of this Notice and take further action as necessary.

[ Show Entire Thread ]