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The following is a response by Michael Cota to the USGS paper. Michael is a herpetologist presently working in SE Asia, who has extensive field experience with Burmese pythons. I think he makes several important points, so I obtained his permission to repost his observations (originally posted on another forum) here:

Having read the on-line available paper thoroughly, having checked many of the references cited that are available to me, as someone that lives in sympatry with the target taxon, Python molurus bivittatus, has traveled extensively through its geographical distribution, and has acquired a great deal of information on this species through personal observations, I find what would amount to pages worth of concerns I have about what was written in the paper. For the sake of brevity, I will keep it to the points that Mr. Reed addressed.

Cheers,
Michael
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Brad Chambers
WWW.HCU-TX.ORG

The Avalanche has already started-it is too late for the pebbles to vote....

Great stuff, thanks for posting. To whom did this response go, however? Will it do any good?

Thanks,
Ed

>>The following is a response by Michael Cota to the USGS paper. Michael is a herpetologist presently working in SE Asia, who has extensive field experience with Burmese pythons. I think he makes several important points, so I obtained his permission to repost his observations (originally posted on another forum) here:
>>
>> Having read the on-line available paper thoroughly, having checked many of the references cited that are available to me, as someone that lives in sympatry with the target taxon, Python molurus bivittatus, has traveled extensively through its geographical distribution, and has acquired a great deal of information on this species through personal observations, I find what would amount to pages worth of concerns I have about what was written in the paper. For the sake of brevity, I will keep it to the points that Mr. Reed addressed.
>>
>>In the paper, it purports that they are found up to ca. 2,400m in elevation. This whole paragraph is not referenced. References listed at the end of their own paper contradict this. My own personal observations, over the past years, which have included significant time at higher elevations in tropical Southeast Asia, also contradict this. At much over 1,000m in tropical Southeast Asia, the ecology turns into one of montane forests, which P. molurus is absent. My apologies to Mr. Reed, but montane forests begin at ca. 1,000m elevation range in tropical Southeast Asia and semi-montane forests below this.
>>
>>Much is done to increase variability in factors by including the extremes in this species, particularly of P. m. molurus, while admitting at the same time the limited genetical diversity in Python molurus present in North America. However, a gross omission is that the problem population of Python molurus in North America is all Python molurus bivittatus from tropical Asia, with the normal phase specimens being of Indonesian blood lines and any with an albino blood line being those that were smuggled out of Thailand. P. m. molurus is far too expensive and rare in collections for people to be throwing away and when was the last time that P. m. bivittatus was imported from China? (never?) Certain bloodlines are going to have less tolerance for climatic variation than others, as the paper suggests. So why was a tropical only bloodline not listed as a limiting factor and shown on the map?
>>
>>A point made here that screams a lack of understanding of this taxon’s biology here is the authors’ lack of understanding why these pythons do not occur in vast areas of the deserts that should otherwise make up their geographical distribution. That is this species’ need of a permanent water source. Mr. Reed mentions people not understanding the tolerances of this python, but I am sorry, this is rather fundamental in the understanding of this species. If you check out their exact locality data in arid climates, you will find some kind of permanent water source available to them nearby (please now erase 95% of the desert southwest in the US from the map).
>>
>>Another error that shows lack of understanding this taxon’s biology is that theory #2 of why this species no longer exists in peninsular Southeast Asia, Sumatra and other areas listed. In this theory, it is claimed that the aggressive nature of P. reticulatus is a probable cause; however, again, this is not referenced with any evidence. Interestingly, in my very own neighborhood, I have both living in sympatry with each other and they can be found in the same microhabitats. This occurs in many areas where the geographical distributions of P. molurus bivittatus and P. reticulatus overlap.
>>
>>While I agree that something needs to be done to control the pythons and they are capable of causing great damage, I think this paper was written in a misleading manner, which is widely open to false interpretations. I sincerely hope that this was not done intentionally, since it appears far more than a mere coincidence that USFWS is presently pushing for a ban on pythons, this paper was just released and it so happens that the media coverage is far greater and faster than what is seen from anything that is not coordinated with the media for a 'media blitz'. The Invasive Species Branch are subject matter experts, their past work has been great and I have had the greatest respect for it; however, I feel this paper will not only ultimately hurt their public image, which it already has, but their professional image, as well. Although there has not been a multitude of people who have had the privilege of learning about this species within their geographical distribution, would it have hurt the authors to ask?
>>
>>Cheers,
>>Michael
>>-----
>>Brad Chambers
>>WWW.HCU-TX.ORG
>>
>>The Avalanche has already started-it is too late for the pebbles to vote....

It was posted on another forum-it was responding to one of the paper's authors.
Will it do any good? Time will tell-it's hard to fight a combination of a media frenzy and politicians looking for a distraction from real problems (which of course they haven't a clue how to solve)....
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Brad Chambers
WWW.HCU-TX.ORG

The Avalanche has already started-it is too late for the pebbles to vote....

Why did USF&W and USGS write such erronious papers?
Well, maybe it was because TP&W got so much mileage out of their fallacious arguments with the turtle trade. It worked for them.
I'm sure you've read all the comments by TP&W justifying their decision. And I'm sure you were there to hear their reasoning.
With all the "qualified voices" in the room, nobody stood up and said a word when they compared the plight of turtles in Bangladesh to those in Texas. Fooled me once shame on you. Fooled me twice, shame on me.
On another note, I'm not so sure sending Red-eared Sliders, Softshells, and Snappers to China is such a bad thing.
If it takes the pressure off of the truely endangered species in the World and those species here are sustainable, I think it is worth considering.
I think you guys confuse your personal dislike of the inhumanity of the Chinese meat Market with the real issues of conservation.
You are putting yourslves in the same boat as those that want to ban all hunting, the fur trade, and the consumption of meat, entirely as morally reprehensible. Sounds like PETA, to me.
There are some realities you just have to accept.
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"As hard as I've tried, just can't NOT do this"
John Crickmer

Sorry guys. Hit the send button by accident.
For the record, I support your work and I am for the protection of Box Turtles as well as many other species.
I just disagree with the way in which it is being done.
So I ask -- please reconsider very carefully your assumptions, alliances, and associations. It's all too common in this country, we delegate assumptions and forfeit our thinking to specialists and authorities. Just because someone in authority says something, doesn't necessarily make it so. This Python thing should make that painfully obvious.
I am lucky to have lived worked and played with so many different foreign nationals in so many foreign countries durring my lifetime. My personal experience tells me things are just not so simple when it comes to competing cultures. Please broaden your outlook. Your very narrow focus is stifling your cause.
Thanks,
jsc
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"As hard as I've tried, just can't NOT do this"
John Crickmer

someone else's characterization of us, rather than what HCU actually stands for. I say this because I don't believe anyone with a real familiarity with the leadership of HCU, their goals and mores included, would ever suggest that PETA and we have ANYTHING in common! I myself am a lifelong hunter and fisherman, and became one of the charter members of HCU because I saw a need for herps to be treated more like game animals and less like a category of species that are considered "endangered until proven otherwise".

That said, we are all realists. We are working in a milieu that includes many professionals who are highly suspicious of commercial exploitation of ANY wildlife. These same people have NO problem with sustainable take of game animals. This is where our hobby can find a space to remain viable in the long term, if that is possible at all (I have to honestly say that if any out there do not recognize that we are in a fight for the very existence of our hobby, then they need to open their eyes!). If we dig in our heels and refuse to negotiate, we will quite certainly lose everything.

As for turtles specifically, many they have several life history characteristics that make many of their species MUCH more vulnerable to exploitation than most other herps. Many turtles are extreme examples of what ecologists call "K-Selected" species. This simply means that each individual lives a very long time, produces relatively few offspring per year, and few of these survive to adulthood to replace the parents. With many species, removal of even a relatively few adults (especially females) can actually drive a population to extinction. Box turtles are one example of such a vulnerable turtle species. They are in trouble in much of Texas, for whatever reason(s). As for the Asian turtle market, exports from Texas won't take ANY pressure off endangered asian turtle-those will continue to be expoited to the last individual to feed the protein-starved masses. They will just be fodder for a limitless appetite.

HCU wants protection for those herps that need it, and regulations on other herps (and herpers) that are minimally restrictive and based on science. I think most reasonable herpers can come to support such an agenda.
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Brad Chambers
WWW.HCU-TX.ORG

The Avalanche has already started-it is too late for the pebbles to vote....

Brad,

You are wrong about many things in your post. The fact that many HCUers are hunters and fisherman is why they should NOT be in charge of a group that represents any part of the herp industry. You look at the “rules” through the eyes of game management. Herps and the herp industry are not like game animals in many ways. In the herp industry, animals are captured alive, possessed, bred and sold (across local, state and federal lines). Game animals are not. They are killed and either mounted or eaten. This is why you don’t get it. Further, your “game management” thinking falls right in line with TPWD thinking which is the WRONG way to think about herps. Now, the management of herps should use wildlife management tools to ensure against over-collection but you have to start by recognizing what the herp industry is and how it functions and it isn’t the same as game management.

All herps have a surplus that can be harvested. For the millionth time, it does not matter what you do with these animals once they are harvested. You can kill them, sell them, eat them or keep them as captives. Just because many in academia and at TPWD don’t get this doesn’t mean you cave in and agree with whatever they say. Just because HCUers want to be “fished in” doesn’t mean the herp industry does. We are talking about a slippery slope. Don’t you understand that? You guys are so naive. There is a difference between refusing to negotiate and standing up for what is right. I will bet any amount of money that if graybands had been listed on the Black List you would be singing a different tune. And you know why they weren’t? Because TPWD knows they would need a ton of data to back it up and they don’t have it. You know why box turtles are? Because box turtle preservation groups have pushed an agenda based on skewed and opinionated papers that stretch the truth.

It is recreational groups like HCU that are causing a divide in the herp industry. Before 2007 the herp industry was a group of people and businesses that included both commercial and recreational folks. Many people crossed the lines of both commercial and recreation. In 2008, we have a splinter group of recreationalists who surrendered to TPWD and do not support commercial folks. You guys are causing the divide but you do not accept that nor do you care. You continue to argue your positions, kissing up to TPWD and pushing the divide and conquer agenda. Thanks! Thanks a lot. People who believe in the right to sell wild caught, the dealers, the importers and the folks who know how bad your agenda is appreciate it. Thanks for being there for the industry and dividing us.

Now, I know you have been “fished in” because of your positions regarding box turtles. You quote the same data skewed, opinion laced papers that were used to outlaw commercial harvest in the first place. Lets look at some quotes from your propaganda:

“This simply means that each individual lives a very long time, produces relatively few offspring per year, and few of these survive to adulthood to replace the parents.”

Box turtles lay between 3 to 7 eggs per clutch and they can have up to three clutches per year. That is a better reproductive rate then graybands and about as much as more fecund snakes. Just because neonate and juvenile box turtles are hard to find does not mean that “few of these survive to adulthood to replace parents.” They are just hard to find because they stay buried much of the time. Researchers have not found a reliable way to discover neonates and juveniles that is all. I have been hunting graybands for nearly 20 years and I have never seen a hatchling in the wild. So should graybands be Black Listed?
“With many species, removal of even a relatively few adults (especially females) can actually drive a population to extinction.”

This is a false statement. If a population is this low then it is doomed. Box turtles are eaten by many animals and killed on roads. If they were this sensitive they would have been extinct long ago. So this is obviously not true. If this were true, box turtles would have been extinct long ago because native Americans have been harvesting them for hundreds of years.

If box turtles are in such bad shape then why are they not listed as Endangered or Threatened? Because they are not in that bad a shape. You see, to place species on protected lists you need data. And the data isn’t there.

By accepting, without question, the box turtle agenda from academics and TPWD you are selling out the hobby. So lets review. HCU and those that support HCU are with academics and TPWD on turtles and the selling of wild caught. You are dividing the hobby and you are giving credence to this agenda by supporting it and selling out your brothers. Why are you doing this? Simple, you guys are selfish and it doesn’t affect you--------yet!

Have a good evening,

Mike Welker
El Paso, TX

And I use that term as in "our hobby will be dead if we take that attitude". Your opinions on this matter is contrary to ALL ecological studies of which I am aware. It is YOU who need to provide data for your peculiar opinions, Mike-and you provide none.

As for Box turtles-you overstimate their reproductive capacity, and underestimate their juvenile mortality (which around here is zero). I say again-in our area, they are all but gone! Just because there are a few left out in the Trans Pecos is no reason to be sanguine.

And your position on management is just contradictory on its face-I won't bother to refute it since it is transparently self-serving.

As for gray bands, I know you wish to paint HCU as a bunch of grayband hunters, but that is not the case and everyone here knows it. I spend my time in the field herping for maximum diversity-the only alterna I ever found was incidentally seen while I was looking for subocs lol!

Maybe you don't mind seeing the herp hobby banned if your right to sell spadefoots isn't preserved, but the rest of us won't be sold down the river for a tiny group of commercial collectors.

Have a good morning.
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Brad Chambers
WWW.HCU-TX.ORG

The Avalanche has already started-it is too late for the pebbles to vote....

Hear, hear! I would like to see your data, Mike. You can talk all you want but where's the all important data?
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Todd Hughes

Having kept a 5th amendment number of box turtles for many years I can see that you do not know a lot about box turtles. Comparing the reproductive rates of a turtle that takes at LEAST 5-7 years to reach sexual maturity (and that figure is being really generous to be quite honest.) and comparing it to a snake that takes what a year or two to reach reproductive age(not 100% sure native colubrids bore me to be honest with you.) is ridiculous to begin with. This is like comparing Parsons chameleons to Panther chameleons reproductively. Secondly where do you get that multi clutching thing from I have gotten countless clutches of box turtle eggs and have yet to have ANY of my females EVER double clutch much less triple clutch. This is not unique to myself either. There is a huge underground network of people here in florida who breed their box turtles and of the several I know I have never heard of multi clutching and I know one guy personally who could write a freakin book on box turtles he knows so much about them, Knowing full well the reproductive strategy of box turtles I can remember a time several years ago seeing a friend of mine unpack a shipment of adult box turtles for his store(they came from texas btw.) It really horrified me knowing that in spite of your ridiculous arguments those kind of numbers are not sustainable . Do I think total bans collecting are the answer NO absolutely not but to allow comercial collection of box turles is just ludicrous. The other extreme is just as bad here in Fl. people are allowed two box turtles per person per household (any of the T. carolina ssp.-T. ornata are not covered.) and breeding is strongly discouraged(prohibited basically) this eliminates a potential source of box turtles for people in the form of babies which is where actual predation should be taking place not with adults which of course leads to the ridiculousness of the 4" rule. You are right box turtles are killed on roads and by predation,( here in fl. the number one killer is bulldozers) but to use those as an excuse for taking an unreasonable number of animals out of a population is just plain stupid.

It appears TPWD is going to allow captive breeding of box turtles. Taken from TPWD's website:

Regulations Committee
Commercial Nongame Species Regulations
Permission to Publish
March 2008
I. Executive Summary: The item presents a proposed rulemaking that would amend the commercial nongame species regulations to:

authorize persons in possession of a nongame dealer permit to breed all species of indigenous turtles in captivity, provided breeding stock is lawfully obtained and the offspring are uniquely and permanently marked;
remove the cornsnake (Pantherophis guttata), the House Mouse (Mus musculus), and the rough-footed mud turtle (Kinosternon hirtipes) from the list of species that may not be used in commercial activity.
II. Discussion: Under Parks and Wildlife Code, Chapter 67, the department is required to develop and administer management programs to ensure the continued ability of nongame species of fish and wildlife to perpetuate themselves successfully, and to conduct ongoing investigations of nongame fish and wildlife to develop information on populations, distribution, habitat needs, limiting factors, and any other biological or ecological data to determine appropriate management and regulatory information. The commission is required to establish any limits on the taking, possession, propagation, transportation, importation, exportation, sale, or offering for sale of nongame fish or wildlife that the department considers necessary to manage the species.

In April of 2007, the Commission adopted new rules to govern commercial activity involving nongame species. The new rules provided a "grandfather" provision for personal collections of animals that had been lawful to possess prior to the new rules but became unlawful to possess under the new rules. Many of these collections seem to be turtles of various species. ***********Staff has determined that such persons should be allowed to breed and sell the offspring of turtles that were lawfully obtained, provided the breeding stock and the offspring are permanently and uniquely marked.***************

Another component of the new rules was a list of species that may not be used in commercial activities. The new rules inadvertently included three species on the list that should not have been placed on the list. Under Parks and Wildlife Code, Chapter 67, nongame wildlife is defined as wildlife indigenous to Texas that is not classified as game animals, game birds, game fish, fur-bearing animals, endangered species, alligators, marine penaeid shrimp, or oysters. Neither the cornsnake nor the house mouse is indigenous to Texas, and the rough-footed mud turtle is already listed as a state-threatened species, which means that it cannot be taken or possessed. All three species should be removed from the list.

http://www.tpwd.state.tx.us/business/feedback/meetings/2008/0327/agenda/regulations_committee/

Thanks. The reason I asked the somewhat rhetorical question is that privately responding to the study's authors and/or rebutting the study on herp forums, imo, will surely do nothing. It seems unlikely this Dr. Rodda guy is going to admit his gross "mistakes" and publicly announce, "whoops, my bad." (Let's not even get into the global warming nonsense the also published. ) If the authors were interested in real science and good-faith debate, the study would never have been published in the first place!

These junk scientists with extremist agendas need to be *publicly* exposed.

Thanks,
Ed

>>It was posted on another forum-it was responding to one of the paper's authors.
>>Will it do any good? Time will tell-it's hard to fight a combination of a media frenzy and politicians looking for a distraction from real problems (which of course they haven't a clue how to solve)....
>>-----
>>Brad Chambers
>>WWW.HCU-TX.ORG
>>
>>The Avalanche has already started-it is too late for the pebbles to vote....

Brad,

Please make sure that you spread this around as widely as possible on the net and otherwise, and encourage Mike Cota to respond publicly in the literature somewhere (as well as on the public comments site USFW/USGS has set up).

Troy

Troy-Yes he's already been encouraged to send this to USFWS, which I'm sure he will do....
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Brad Chambers
WWW.HCU-TX.ORG

The Avalanche has already started-it is too late for the pebbles to vote....

contact me privately. I have something important to discuss....239-645-9661 or herpsltd@bellsouth.net...thanks...TC

Tom,
If Brad doesn't see this, call me and I'll give you his number

Randal