I am going to use the info provided above and send this one as a word document!!! I have posted it here, full length so that people can see it, and see what I have added to it, in part due to the information you have provided.

Dear USFW service,

My name is ____________________, and I would like to add comment about the current proposed rule changes regarding the 9 species of large constrictor to the Injurious Wildlife list. I believe these changes are not only unnecessary, and virtually useless in regards to eradicating these animals from where they have become established, but that they would be catastrophic for my hobby and many of my friends and peers. I keep a few of the snakes that are on the list myself (Albino Burmese Pythons & Boa Constrictors). I teach with my snakes, educating people about wildlife, and animals around the world and they help provide income to me this way. These animals also provide me with an enjoyable hobby, and they are my companion animals, as I am allergic to cats and dogs, and snakes provide a hypoallergenic choice for pet animals.

I believe that these proposed regulations are an unnecessary infringement on the rights of American citizens, and seeing as they will be financially damaging to many small business owners who keep, work with and breed and sell these animals, it is concerning to see a general lack of any tangible scientific proof that they will actually help stop or prevent the situation in Florida, the only state in the united states that any of these snakes have ever survived in anything close to a feral situation. These regulation on the snakes will cause a financial strain in multiple economies. Not only will import and export tariffs from the hundreds of thousands of imported and exported animals each year be lost, so too will the jobs of thousands of people both in our country and in Africa and South America. We will loose, in effect, an entire economy; the export and import of these animals is a major source of income for many people, and many businesses would go out of business without the ability to import and export these animals. I could be included to agree that with animals common in the hobby, like the Reticulated Python, Burmese Pythons and Boa Constrictors, there is no real need to continue to import large numbers of wild caught animals, as we have an ample captive population to provide folks with high quality animals. Surely a restriction can be made if that is the goal that would still allow folks to sell and trade in the animals between states. I know that one can not import European Starlings or Hill or Common Myna birds, but they can still be legally sold and traded in the continental United States, between states that allow their keeping and breeding. A tariff or regulation that limited the number of new animals brought into the country that would still allow breeders to bring in new blood and higher end captive produced examples of the species would be a great idea in my opinion.

Many businesses which breed fine, high quality reptiles in the USA and sell in the USA exclusively, but ship the animals out of state to make more sales, and these folks would suffer an enormous cut in profits, and could end up loosing their businesses and livelihoods as well due to this change. Not only are pet owners, hobbyists and breeders and importers affected by this change, so too will all retail stores featuring reptiles and the reptile care equipment that goes along with keeping these 9 species of snakes. Reptile keeping supports a BILLION dollar a year industry including rodent production as feed, many specialty cage producers, the husbandry equipment manufacturers, and the exotic animal veterinarians to name a few. Many other people who work with and breed reptiles of other species attend reptile shows and sell animals and network there. Many of these shows feature Boa Constrictors and Burmese Pythons, 2 species that are very common, and often expensive, and both would be banned from interstate travel by this rule change. Both of these species can make fine pets. As the vendors and breeders of these animals are no longer allowed to bring their snakes to out of state shows, the major, and minor, reptile shows could cease to be, and the other vendors will suffer as well, as for some a majority of their sales are at such shows. If this rule change goes into effect, it would threaten this viable, profitable US industry and would reach from the hobbyist to the researcher, zoos, TV & film, specialty parks, museums, and even the fashion industry.

To enact a change in regulations that affects the interstate transportation will just create yet another black market that will require policing, along with making citizens who move to another state with their pet Python, or Boa Constrictor, criminals. If you make it illegal for people to move to a new home with their pet in another state, how many of those pets might end up released into the wild anyway? If these people reside in South Florida, there is the chance that it would mean even more animals released into the wild into the present population. I think it more likely people would break the new law to bring their beloved pets with them. No matter which, I believe this change will be bad for people, and our state, and it will be bad for jobs, including mine & my vets. Here in Pennsylvania there are currently no statewide restrictions on any of these species. The same goes for Maryland, where my animals regularly go to my vet of choice. The restrictions you are proposing will make it illegal for me cross state lines and will make it illegal for me to take my snakes to my vet. I will no longer be able to legally take my animals to educational programs or entertainment venues where I have to cross state lines, and this will negatively impact my business.

Under the current regulation, 9 species are banned. These species consist of the Indian Python, Burmese Python, African Rock Python, Green Anaconda, Yellow Anaconda, and Boa Constrictor, along with 2 virtually unknown species of Anaconda. I am greatly concerned that this would be expanded to include others. I know that the HSUS (Humane Society of the United States, an Animal Rights Organization who wants to see an end to all animal use - pet ownership, farming, hunting, and so on) pushed for the Boa constrictor to be on that list, and it was so added. Many in the reptile hobby feel that there is a huge animal rights agenda push behind the current media frenzy regarding these snakes and the push to ban them. This is fully supported by the push the animal rights group have to encourage the banning of these animals. They want to see all exotic animal ownership banned, (well, in reality, they want to see all animal ownership banned, period!) and many see this as a fist step to help take down the reptile industry. Some very distorted and blatantly nonfactual information is being repeated and used by those groups, claiming all sorts of crazy reasons these animals should be banned. Judging by the responses you have recieved to this rule change, I don't think I have to continue to detail some of what these folks have had to add, as you will be able to read them directly.

Boa constrictors, one of the species being called a "giant snake" normally do not grow longer than 7-8 feet in length, for example. These snakes have not ever killed their keepers, nor have they killed anyone else. There has NEVER been a documented death by a Boa Constrictor, and these animals are even more fragile then the pythons when it comes to temperature variations. A naturally occurring form of the Boa constrictor is found in the Sonora Desert in Mexico, not all that far from the US border. I would expect if these animals were going to surge forward and establish in the USA they would have done so already. I am a keeper of some of these animals and have never had an issue with these snakes escaping. I have spent some rather large sums of money purchasing specialty caging, designed for these animals, which makes it impossible for the snakes to escape, and makes them easy to properly maintain. These cages are American made, and built to make it so snakes stay put. Many have locking glass doors (Vision cages, for example) while others have doors that latch to the unit themselves (Like Animal Plastics & Boaphile) I have never had my animals escape. The money that I spend on such cages and equipment goes right back into our struggling economy. Making the purchase of cages that lock for large constricting snakes a requirement would be a good goal, especially in Florida. The ROC laws that were going in place in the state of Florida covered this, and also required the animals be microchipped. That is a great way to make keepers in such a state responsable for individual specimens, as they will remain tagged for life.

The species like the Burmese Python, Indian Python, African Rock Python, Reticulated Python, and Green Anaconda can get large, and some of these are kept by many people across the United States. Burmese pythons are known for their docile temperaments, and as I have already stated, they are often kept as pets. Reticulated Pythons are often kept as captives too, and like Burmese Pythons, many captive color forms of these animals have been established, and some are worth large amounts of money. Breeders invest large sums of time, money, and energy into producing lovely, tame pet snakes for the hobby. These snakes are often kept not only as pets, but as investment animals, much as one would keep show dogs, cats, or horses. Many people in this state breed these snakes, particularly the Boa Constrictor, Burmese Python and Reticulated Python.

It is true that the individual species that can become "Giant" snakes (those exceeding 16' in length) can, and do occasionally harm their keepers. Statistically, though, the chances of being harmed by these snakes when they are kept responsibly are small and they are no more dangerous to their keepers then many other commonly held creatures, including domestic animals like dogs, horses, or cattle. Anyone who chooses to live with or work with large animals, be they the larger breeds of dog, animals like horses, cattle, or giant snakes is, or should be aware that they can be harmed by these animals if they are thoughtless while managing them. Captive Burmese pythons, Indian Pythons, African rock pythons, Reticulated Pythons, and Anacondas do not pose any sort of significant or epidemic threat to Americans. A better argument based on safety & health statistics could be made to ban horses or dogs. I bring this up specifically because much has been made of the tragic death of Shaiunna Hare, who some believe was killed by a family's non properly caged, emaciated, albino Burmese Python. The autopsy determined that the child died by asphyxiation, meaning that the snake might have well been responsible, but the most responsible party were the oblivious parents who would keep an animal like that without any sort of real enclosure, with absolutely no regard for their daughters safety. The parents had some other serious warning sighns that they were not responsable owners for this reptile, nor responsable parents for poor little Shaiunna. While it is a terrable shame that this happened, and most certainly wouldn't have in a responsible reptile keepers home, we do have to acknowladge that living along side animals that we call pets has a certain degree of danger, especially to the youngest of us. Its a parents job to make sure that things like the above don't happen. For those who think that an incident involving a python killing a youngster being is a good enough reason to ban these snakes from being held as pets, we should absolutely see to banning the ownership of dogs in the state of Florida, on the grounds of safety first! Many florida children & citizens have died in the mouths of canines, the very animals dubbed "mans best friend". In Florida in 2009, on Dec. 12, 22-month-old Dallas Lee Walters was mauled to death by a relative's Rottweiler-Labrador mix during a birthday party, and the same year the Perk families beloved Weimeraner killed their 2 year old son Liam at their home in Cape Coral with a brutal neck bite. Just this past month, Sidon, a pit bull mix, attacked and killed newborn Thomas Carter Jr. in the Moon Lake Estates area of Pasco County & in Oak, the three year old daughter of Lori Haaker, owner of Haaker's Dream Bulldog Ranch & a National Kennel Club judge of American bulldogs, was recently killed by one of her dogs as well. Are these (and I'd note, rather numerous when compared to Florida's single large constricting snake death on record) incidents a good reason to ban dogs? I don't think so, and most dog owners would not think so, but they should make people more aware of the potential dangerous their pets could be if not managed, trained or kept properly.

The feral population of Burmese Pythons does not appear to pose a real or significant threat to human beings at this time, and its unlikely due to the nature of these snakes, that they will become any sort of significant threat. These pythons appear to spend most of the time where they are around people trying to avoid them. The environmental concerns of these animals regarding damage to wildlife populations or agriculture certainly do not even apply in colder states because all of the species listed, would not be able to survive a single winter, let alone a fall or even a chilly spring. As you are surely aware, we had some record cold temperatures in the USA this past winter, and I am sure that those are helping cull the feral animals even in South Florida. A recent statement from a person involved with the study of the wild population indicated that 9 out of 10 of the snakes that were being tracked died after the freeze this past winter. These snakes can be fragile when exposed to significant temperature variations. Florida, particularly South Florida is unique in being one of the only ecosystems in America where any of these snakes can survive, let alone thrive, and reproduce without the aid of a keeper. If those animals have been there long enough to establish and breed, and it is the fault of individual pet owners dumping over sized or unwanted specimens, I would wonder how they had not established any where else if they could. For reference, if any of the snakes in this list of 9 were released here, there would be no cost to eradicate any of these animals in the state of Pennsylvania, as the fall weather, followed by winter freeze would do that job quite efficiently, for free. There are no animals the snakes could really threaten here, at least long term, because of the variable temperatures. The surruonding states of New York, New Jersey, Ohio, West Virginia, Vigrinia, Maryland & Deleware and are also too cold for any of these animals to survive or establish. Even in the warm state of South Carolina, where in Aiken a SREL study was being done on these animals gets too cold for these animals to make the winter. (There is/was a study being done, but they have not been kind enough to release the details of what happened to the animals in a timely manner) I have to be careful about keeping my snakes warm and cozy in the wintertime, as do all of the keepers who have these animals outside of extreme South Florida. I have to purcahse heating suplies like fiberglass heat mats and ceramic heat coils to tend to my charges tropical requirments. The last python hunt came up with no snakes found. Clearly the cold from this winter kocked them back, if not eradicated the animals, at least from most of the range where they had become established.

The Burmese Python (Python bivittatus, formerly Python molurus bivittatus) is not the same snake as the Indian Python (Python m. molurus). As a matter of fact, the Indian Python is ALREADY a restricted species in the united states, and can not be sold or moved across state lines as they are recognized as a CITES 1 Endangered Species. As quoted from the The Center for North American Herpetology, "The taxonomic status of the Burmese Python (Python molurus bivittatus) is reassessed and elevated to specific rank again. The population from Sulawesi, Indonesia, is a dwarf form of this giant snake that is redefined as Python bivittatus progschai ssp. n." It goes on to say that "both maintain their phenotypic identities without interbreeding in nature. This argues strongly for selective pressures against hybridization, which is what we regard as typical for incipient speciation." - Indicating that even in the wild state, where these 2 close species live, hybrids are uncommon. I know some people were very concerned about the feral Burmese Pythons that were in Florida hybridizing with the Rock Pythons that have been found, but that is also quite unlikely. When the 2 species were crossed in captivity, it was very hard to do, and the hatchlings did poorly and lacked vigor. None of these snakes on the listing can hybridize with any of our native animals, so that is not a worry.

The origin of the population of Burmese Pythons found feral in the everglades is also somewhat confusing. It is commonly attributed to pet keepers dumping their large Burmese pythons in the wild after they become unmanageable. There have not been any captive morphs of this species found outside of a few tame individuals in more urban areas, clearly lost, or released pets. We know that folks have staged captures of released snakes, as well, like happened with Justin Matthews, where he released a Burmese Python and then made a fiasco about finding and capturing the animals for the media. I have overheard animal rights minded folks talking about releasing these animals, and then calling authorities and reporting spotting them in an attempt to garner power to the cause of bans. Captive Burmese pythons come in many mutant color forms, and while some might be more prone to predation then others (such as the albino animals) many other forms are not (Greens, Labyrinths, Striped, and so on), and yet the population of feral animals does not represent these specimens. If the population of these snakes was really that of pet keepers dumping their animals like many people keep saying, and I believe a primary reason this regulation change is being proposed, one would certainly expect to see some morphs turning up, as even standard wild colored captive animals are very often heterozygous for one, or more of these traits. That leads many on the herp hobby to think these animals are likely of much older origin, prior to the establishment of the various morphs in captivity, and not, as is commonly stated, the continuous dumping of unwanted pet animals who have become too large. It seems more likely these animals owe their existence to a defunct or careless roadside zoo, or a sloppy importer with poor control practices. The snakes there may even be the result of animals that escaped places like Everglades Outpost, a reptile and exotic zoo, located quite close to the feral population during hurricane events. It has been stated by many that that hurricane Andrew may have played a large part in this population of animals. If we are going to just make the assumption that this population of Burmese pythons is one that is due to pet owners who carelessly dump their animals, it also seems quite strange that the center for this population is some of the most policed and regulated parts of the Everglades National Park system.

I am understand that Florida is VERY concerned about the number of feral Burmese pythons found there, particularly because they are situated in the Everglades National Park. Invasive plants and animals can be very damaging to wildlife and wildlife habitats, along with agriculture. Florida has a problem with non native species not in any way limited to pythons. Pythons, Iguanas, and Nile Monitors have been the subjects of quite "sensational" news stories and articles. Pythons, specifically the Burmese Python, have made the news more and more, and that is why so much public attention is focused on them. There are very exaggerated claims of these animals eating large pets and "biting the heads off" of other animals. As anyone familiar with snake biology knows, this is not only implausible, but, an impossibility. "Giant killer snakes in your backyard" sells headlines, plain and simple. I am sure that the populations of introduced pythons pale (I hear the estimates, and have a feeling they are widely exaggerated) when compared to populations of other species in the state of Florida, but that is no reason to ignore the growing population of Burmese Pythons that are present. I will mention that the state of Florida has many other introduced reptiles & amphibians, introduced parrots, passerines, and various mammal species including feral cats and dogs. Florida waters teem with introduced fish species, and feral cat colonies are present in some of the prime habitat for migratory and nesting shore birds, which they readily prey upon. These cats are allowed to continue to exist and pressure the already stressed, and in some cases endangered native birds, and native reptiles at great cost. Pythons keep getting quoted as having taken 2 of the Key Largo Wood Rats, an endangered species, but for some reason people don't seem to mention the enormous feral cat colony that exists right in the same area. Pythons, like the cats, have no reason to hunt native Woodrats over the feral Black & Brown rats, or even the introduced Gambian Pouched Rat. Unfortunately for the Woodrat, it is low on the food chain, and native snakes & raptors enjoy them & their young for dinner as often as the pythons and cats do. Nutria compete with muskrats in the northern 2/3 of the state. In the everglades, and throughout the southern USA, feral hogs are causing immense amounts of ecological damage. The Red eared Slider Turtle is an invasive animal not only in Florida, but over much of North America, and even the world, as is the Cane Toad, a species that did finally establish due to a pet trade release, but prior to that, attempts were made to establish it by officials. We know that some of these animals can cause great ecological impact, and, at least in the case of feral cats, can even drive native species to extinction. I hear the news and scientists claiming that the Burmese Python and these other snakes will destroy the "pristine" and "intact" everglades. In matter of fact, there is hardly anything of the "real" everglades left, if anything at all. The Florida Water Management folks along with development and roads, dikes and diversions have completely changed the water system. These snakes, and the people who own and breed them are being used as a convenient scapegoat for the ails of the Everglades, while in fact they are just a tiny blip of a problem on the enormous problems that part of Florida is actually facing. Restoring the proper flow of water through the everglades would be a great start to repairing a system we have been destroying for hundreds of years.

I would also like to add that we currently have NOT been provided good, peer reviewed, scientific proof, findings or evidence that any of these species of snakes in this proposal can establish outside of South Florida, let alone cause great ecological or agricultural impact even IN South Florida. I can't imagine these animals as having any significant agricultural impact in South Florida either. They might even aid farmers by eating animals that predate fruit crops. As I am currently aware, we don't even know what is going on with the introduced Burmese Python in South Florida regarding the animals it lives alongside, and while I have seen much written estimating the damage they could and will cause, (some of them so absurd and exaggerated beyond all reason-ability, the USGS map being the prime example, along with comments like "the water could be crystal clear, and all we would have are these snakes" - what in the world would they be eating then! Burmese pythons don't eat each other!) I have not seen any valid scientific findings regarding what animals they prey upon, or what species they are putting any specific predatory pressures on over any other. We do know many animals native to South Florida prey on snakes, and there is no reason to think that young or juvenile Burmese Pythons are exempt from ending up food, just as the native snakes would. There is no reason to think that ophiophagous snakes like the Florida Kingsnake do not add the Burmese python to its diet, and that the similally inclined Striped Skunks & Mink don't do the same. These snakes might compete with some of the larger native snakes, (The Eastern Diamondback Rattlesnake & the Indigo Snake are the 2 large species I am thinking of) but its just as likely that they do not share the same ecological niches. The Indigo is a very rare snake, mostly due to the destruction of its required habitat, but unlike the snakes listed on this rule change, it is an active diurnal predator, while they tend to be nocturnal stealth hunters. The Rattlesnake might share some of the same prey preferences as the Burmese Pythons at some point in their lives (that being primarily warmblooded animals of substantial size). Most of Florida's other native snake species are smaller, and don't seem to have the same niches as any of these large snakes, except for the period of times these large snakes are babies.

Unlike the only other reptile species currently listed by the USFW as banned, the hardy and adaptable (and proven invasive, with catastrophic results in Guam) Brown Tree Snake (Boiga irregularis), NONE of the snakes listed on this proposal have proven to establish themselves as invasive animals elsewhere in the world either. Brown Tree Snakes belong to the genus Boigia - all of which are mildly venomous, rear fanged colubrid snakes, typically known as the cat-eyed snakes. These animals are distantly related to the snakes listed in this rule change. There are 33 recognized species in the genus Bogia, and 32 of them are not banned. The Gold-ringed Cat Snake or Mangrove Snake, Bogia dendrophilia is a fairly common captive animal, and has not become an invasive animal.

In Guam, and the other small islands in the southeast pacific where the Brown Tree Snake have become established we know that this species of snake of the genus Bogia is particularly destructive. The island of Guam lacks native snakes or predators that can deal with snakes the size and aggressiveness of the Brown Tree Snake. The risk to Hawaii, another island, from the Brown Tree Snake is very real, and there is already regulation in place to prevent the keeping, importation and transport of any snakes to the state of Hawaii, which has almost as many problems with tropical invasive species as Florida. We already know from various photographs and bits of footage that the American Alligator will consume the Burmese Python, and I am certain that many other predators do as well, at least while they are young. While the Burmese Pythons surely do consume native species such as rodents, wading birds, waterfowl, Muskrats, Rabbits, Opossum, Raccoons, and even Bobcats & White Tailed Deer, they are probably just as likely to predate the more common exotic species such as feral Cats & Dogs, Nonnative Rats and Mice, feral Hogs, Starlings, Pigeons, Collared Doves, Spiny Tailed Iguanas, Green Iguanas, Cattle Egrets, and Muscovy Ducks to name a few. The Burmese Python, if it did survive this past freeze might be as much of a control measure to the other exotic species in the glades as it is a "nuisance" to the natives - We just don't know. This, and much more goes to show that there is little comparison between the Brown Tree Snake and any of the 9 snakes listed in this proposal.

This regulation change will not make the established population of Burmese Pythons disappear, nor do I believe it will in any way lessen the animals that are present in the glades. Florida needs to handle the animals that are a problem in Florida, as that is exactly what some reptiles are to Florida. As I mentioned above, Florida had recently instated a permit system that will be required to possess certain reptiles of concern, including these species. They didn't give it any time to "work", and just recently passed an all out ban on the "Reptiles of Concern". This rule change will make the animals people have illegal, but will not prevent folks from then illegally dumping their now valueless animals who they can no longer legally sell, trade, or rehome. I find it despicable that in that situation, these animals, some of which are extremely valuable, have just been made monetarily worthless overnight, due to a law change, and the folks who purchased them legally with thier hard earned money, or bred them legally before, now have no chance or hope for government or state financial compensation for their loss of these investments. I hope I am never in that situation, as I know it would have me angry and upset. With bans like that passing, I would be VERY concerned about folks releasing those animals into the everglades or other wild places in Florida (or elsewhere) simply out of outrage or an act of civil disobediance that they have had the rights to their property stripped from them, and have now had the ability to recoup thier losses taken from them. I know that Florida provides a "Pet Amnesty Day" where people can turn over animals with no questions asked, but for someone who might have spent $1,000.00 or more for a high end "desighner" animal, that is quite a disapointing turn of events, especially considering the state of the economy. Once more I will add that Florida, and specifically South Florida has the distinction of being the only place that has suitable climate and habitat that these tropical animals - the 9 snakes listed in this change, -could survive in the wild in the continental United States. Florida needs to punish the people who do release invasive species into the wild as the environmental terrorist that they are, and work on eradicating the established invasive non native pythons and species that are there. That goes for errant or careless keepers, to people trying to stir media attention to sloppy importers. Banning the species from interstate trade and travel is making a widespread rule change that negatively affects thousands of people all across the United States for a very localized (Florida) problem.

I am of course concerned over Florida's ecology and the native species that these introduced snakes consume, and this that the best course of action would be an eradication program, possibly with a bounty. We managed to wipe out the Grey Wolf, Grizzly Bear, and many other species (oops) with such programs in our country's past, and it would possibly be a very effective tool to apply to this situation. I will add that getting more people involved from the herp community/industry would be a very good thing regarding the control of these animals. I suggest that there be an open season with no take limits on these feral animals (all of Florida's reptiles of concern, and for that matter, any non native feral species that Florida wished to see removed from its wilds) year round, so that what is left of the population can be eradicated, or at least intensely and seriously controlled by interested parties. We already know their hides of these animals are valuable, and are exported from the native countries of these animals in numbers. People in the fashion and leather industry will pay good money for these homegrown "ecologically friendly" snake skins. With proper use & respect for the land, there should be no serious impact on non target species if these animals are managed in this way. Having people who are well versed in snake identification and behavior with respect for serpents, in my opinion, would be very important so that non target (native) snakes would not suffer the fate of being killed via mistaken identification, or simply kill happy sportsmen, and that only the Pythons or other feral species would be culled.

Is there any action that might prevent still more species of plants and animals from establishing in South Florida? I, along with many other reptile hobbyists do see one very practical solution.

Miami is the primary American port of entry for imported plants and animals, especially tropical plants and animals. Because of this, Miami is full of and surrounded by wholesalers and distributors of exotic plants and animals. At any given time, an inventory of exotic plants and animals with a cumulative value in the hundreds of millions of dollars can be found in Miami. Florida has made a lot of money from the importation business. Every shipment, every box, is stamped and cleared by USFWS, Customs, and for some cargo, even USDA. Some plants and animals come into the port and are nearly immediately shipped on to other destinations in the United States. Others, including exotic trees, fruits, palms, cycads, vegetables, ornamental shrubberies, exotic grasses, reptiles, mammals, birds, and tropical fish are maintained in South Florida for commercial propagation, agriculture, and captive breeding. Miami is literally seething with exotic species, both Flora and Fauna, as captives, and as feral.

The main problem is that South Florida has the most tropical climate in the continental United States. As I said above, these snakes on the list really wouldn't have a chance to establish anywhere else, or they would be there already. Many species of escaped plants and animals thrive outside the nurseries and cages of the distributors and wholesalers in South Florida though. Released and breeding in South Florida are literally thousands of species, most of which can survive anywhere else in the United States. And it's all because Miami is such a primary port of entry. I would think a very reasonable solution, rather then banning those animals, would be to remove the status of the Port of Miami as an agricultural port and a port of entry. Move the port of entry north, maybe to one of the New England ports where the weather will eradicate anything that would be lost or illegally released.

There is no reason to pass regulation that would not further preventing the establishment of any of these
species, as in the rest of the USA outside of South Florida it is not even possible for any of the 9 species listed on to become an invasive species. The USGS report (and map) being used as justification for these Draconian measures has been characterized by independent scientists as "unscientific" and "not suitable as the basis for legislative or regulatory policies". All statements and conclusions regarding the potential and the consequences of the nine species to establish are grossly exaggerated. It is not to the credit of the USGS that this report was, as stated by Dr. Haseltine, reviewed by research managers and scientists employed by USGS.

It is not hard to understand why the USGS and biologists would be strongly interested in seeing nine more species added to the Injurious Wildlife List. They have decades of experience getting funding for injurious snake research-they are expert at it. Because of this history and the fiscal incentives involved, there exists a tangible potential for bias, impropriety and a lack of impartiality. Due to the obvious possibility of conflict of interest and bias, the USGS should have recused itself from the contract and funding to create this report. So far, the USGS "report" provides the ONLY "scientific" evidence, (if one can call it that), that would justify any federal regulatory action regarding these nine tropical snake species. Otherwise, it seems all the current and legitimate scientific evidence indicates that they are only a problem in and to South Florida.

That being the case, there is no reason to use such sloppy "guesswork" as the USGS map to support this change of regulation, especially with such a potential for this to negatively affect so many responsible keepers, breeders and pet owners, that have maintained and bred these species safely, humanely and responsibly for decades by destroying them financially and personally, by eradicating both their hobby and livelihood. As I said above, these regulations not only affect the breeders of these animals and people who deal in them, but it will cause serious problems even for the private pet owner with a few pet animals, as it will take away their right to move with their pets over state lines, and they will even be prevented from legally taking their animals to their veterinarian of choice if crossing state lines is involved.

Please take these things into consideration while you are addressing this situation.

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