...for whatever it is worth. I did not feel like I could answer many of the questions directly so I tried to take a broad approach. We'll see what happens next.

To Whom it May Concern:

My name is Rob Lewis and I am writing in response to the above referenced NOI. For the past 15 years I have been actively involved as a hobbyist in the keeping and breeding of reptiles. For seven of those 15 years I was employed as an animal keeper caring for several species within the genera Python, Boa and Eunectes. While I am not a scientist by training, it has been my responsibility over the past 15 years to educate myself to the best of my ability regarding the natural history and captive requirements of the animals in my care.

As a hobbyist, I am not privy to the information required to answer many of your questions accurately. However, there are some points that I would like to address in addition to expressing my concern over the potential restrictions that could result from listing (particularly at the genus level) these animals as injurious.

As a former resident of the state of Florida, I am fully aware of the issue of introduced wildlife (an issue that extends far beyond the three genera being investigated here) and the potential impact that it could have on native wildlife. However, having also lived in several other east coast locations, and given my understanding of the natural history of the animals in question, it is my belief that South Florida is one of the few places in the US that a population of tropical reptiles could become established. In Pennsylvania, my current state of residence, for example, the winters are much too harsh to allow species in the genera Python, Boa and Eunectes to survive, let alone establish a viable population. To me, this fact alone should relegate this issue to one handled at the state level and I am aware of laws recently enacted in Florida to do just that. To list these genera as invasive at the federal level would needlessly subject the residents of Pennsylvania, and the majority of states in the US, to burdensome regulations that are just unnecessary.

As for the business questions you have asked, as one hobbyist I am simply not privy to specific information regarding the size of the reptile industry and would not want to guess and put forth meaningless numbers. However, I have attended numerous reptile shows over the past 15 years and have witnessed the growth of these shows in that time. Many of the breeders that attend these shows travel great distances and from other states to attend. Given that observation, I would estimate that any restriction in the interstate commerce of these animals would have a significant economic impact. For some it may even significantly impact their ability to earn a living.

As stated above, I have spent the past 15 years educating myself on the habits, lifestyles, habitat needs and physiological needs of many of the species in the three genera mentioned. Given that knowledge, it is my belief that the impact of any of these species on native species in the US is minimal (when considered at the federal level) and restricted to a very small portion of the country. In addition, the state of Florida (the only state to my knowledge with suitable conditions for these species to invade) has recently enacted regulations to address this issue. Restricting these animals at the federal level will needlessly limit trade, therefore having adverse economic impact, and do little, if anything, to actually address the issue of invasive species.

I appreciate the opportunity to participate in this process and will be following this issue closely.

Sincerely,

Robert Lewis

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