Reptile & Amphibian Forums

I've started to research the proposed USF&WS rule change for all amphibians:

"Abstract: We are reviewing a petition to add all traded live amphibians or their eggs to our list of injurious wildlife under the Lacey Act unless certified as free of Batrachochytrium dendrobatidis (chytrid fungus). The importation and introduction of live amphibians infected with chytrid fungus into U.S. natural ecosystems may pose a threat to the interests of U.S. agriculture, fisheries, and commerce, as well as to the welfare and survival of wildlife and wildlife resources. For live amphibians or their eggs infected with chytrid fungus, an injurious wildlife listing would prohibit the importation into, or transportation between, States, the District of Columbia, the Commonwealth of Puerto Rico, or any U.S. territory or possession by any means, without a permit. Permits may be issued for scientific, medical, educational, or zoological purposes."

Source: View Rule Change

The emphasis in bold is mine.

I've emphasized the most important aspects of this rule change in bold. Let's analyse what the bold parts mean to amphibian hobbyists:

1. "add all traded live amphibians or their eggs to our list of injurious wildlife under the Lacey Act" means 2. "an injurious wildlife listing would prohibit the importation into, or transportation between, States, the District of Columbia, the Commonwealth of Puerto Rico, or any U.S. territory or possession"

Something is missing... ah yes, "unless certified as free of Batrachochytrium dendrobatidis (chytrid fungus)".

This raises a lot of questions: 1. Who qualifies for certification? 2. Who will perform the certification? 3. How will the certification be conducted? 4. How much will it cost? 5. How long will it take? 6. How often does it have to be done? 7. Where will the certification take place?

Here's some information that may be of use in fighting this proposed rule change:

"Trade and transport of amphibians by zoos also is set to increase in direct response to the emergence of Bd. The AmphibianConservation Action Plan (ACAP, amphibia web.org/declines/acap.pdf) specifically calls for captive breeding programs targeted at species that are at high risk of extinction in the wild due to chytridiomycosis, habitat destruction, and other threats. In response to this call, the Amphibian Ark was formed tomobilize zoos internationally to develop ex situ captive breeding programmes. It is generally recognized that captive breedingwithin native species ranges is, to a large extent, logistically impossible to implement, maintain, and biosecure. Instead, regional centers are required that, as with Xenopus, concentrate captive breeding capacity, which is a fundamental component of the Amphibian Ark program. We agree that quarantine procedures need to be set in place, becausemany species coming into these breeding programs are or will be affected by infectious diseases, and those already present in zoos are at risk of cross-infection if biosecurity is not maintained (Walker et al., 2008). However, most accredited zoos have such procedures in place, although there is a need to upgrade and standardize. As well, synergies amongst components of the amphibian trade may actually benefit this global conservation effort. Many species in the pet trade are closely related both phylogenetically and ecologically to important target conservation species. These species can be used to train staff at regional centers so that when target species are brought into captivity the likelihood of successful ex situ programs will improve. In cases where target species are in the pet trade, they may prove to be the best or only source of breeding stock. This is no small beer; most zoos have far better developed reptile husbandry and very few institutions boast of breeders and keepers who are specialized in amphibian care, health, and reproduction. Some zoos are already using amphibians purchased from the private sector to develop the skills necessary to implement the Amphibian Ark plans. From a conservation perspective, this is not the time to alienate the pet trade sector, which may be the most useful repository of captive breeding and husbandry know-how and arguably has the greatest success rate at breeding rare, difficult to keep, and difficult to breed species.

Given that the amphibian trade is already enormous in the United States, Asia, and Europe (Schlaepfer et al., 2005; Tyler et al., 2007) and the pet trade is rapidly emerging in Asia (Rowley et al., 2007), blanket bans and radical restrictions are going to be impossible to implement. Imposing trade restrictions will require substantial time and effort with no guarantee of success and may result in a substantial increase in unregulated trade. The better and more rapid option is to regulate trade for the control of the spread of infectious disease. Strategies for this are in place in most countries and should easily be modified for amphibians. For example, on Dominica, agricultural trade has already been modified to reduce the risk of transporting amphibians passively around the Lesser Antilles. Toward this, the Aquatic Animal Health Code of the World Organization for Animal Health (WOAH, or the OIE) has been amended this year to include both Bd and ranavirus and now includes recommendations for certifying disease status of countries and amphibian products. By using the WOAH guidelines, we believe that the risk of disease transport will be, to a great extent, eliminated. For certain cases (e.g., Madagascar), more stringent restrictions may be put in place. Along with trade regulations, we need to educate stakeholders in the amphibian trade about the risk of pathogens to wild populations and to their livelihoods. Many amphibian traders, notably those in the pet trade, currently feel alienated from zoos and the scientific community but would welcome the opportunity to increase their knowledge of infectious diseases and implement better practices. Our research has shown pet traders in the United Kingdom feel that there is a lack of available information regarding the risk of amphibian infectious disease; however, the majority of pet shop owners surveyed feel import regulations are not stringent enough!"

Source: www.savethefrogs.com/kerry-kriger/pdfs/Garner-2009-Reply-to-Kriger.pdf

The emphasis in bold is mine.

A typical ploy used by animal rights organizations is to lump the trade of all amphibians together, as if all amphibians are equally responsible for the spread of Chytrid Fungus. Combining Dart Frog data with Bull Frog data is a good example of the use of this tactic.

Stay Alert - Be Aware!

"A typical ploy used by animal rights organizations is to lump the trade of all amphibians together, as if all amphibians are equally responsible for the spread of Chytrid Fungus. Combining Dart Frog data with Bull Frog data is a good example of the use of this tactic."

Just a part of their SMOKE AND MIRRORS tactics.

Most people [here] should be able to identify their propaganda just by the ever present technical leaps and the liberties they take with facts, truth, reality.

jsc
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"As hard as I've tried, just can't NOT do this"
John Crickmer

That is SOP for the AR people...GUILT BY ASSOCIATION. Their bread and butter.
jsc
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"As hard as I've tried, just can't NOT do this"
John Crickmer

The same thing with the box turtle laws in Texas. They said if you sign there petition it would stop the trade of turtles to China food markets. They failed to mention that box turtles were not on the list of species being sold to China. But they did say the number of turtles being sent and I can't remember the exact number but it was in the thousands. They worded it to make people believe the thousands being sent were box turtles so you would of coarse do the right thing and sign the petition. Not knowing that box turtles were not being sent at all according to the list of turtles they got the numbers from.
The original document of this disappeared after I called it out. But it was too late because bunches of people signed the petition under what I would say was false pretences and maybe even fraud since they were being lied to.
The irony here is the turtle species that were being sold most to the Asian food market were red eared slider, soft shells and snappers. They got exempted so they could still be sold to the food market while the box turtle breeders got the shaft. I do not see any conservation in that at all.
At the time nobody would really listen to me and some of you guys called me a winner. Who is winning now? The way I see it is it is not winning if you have a legitimate reason for your complaint and it is all true.

They have a way of limping things together and trying to make information look like it applies that doesn't.
They also have a way of attacking one type of animal keepers at a time in separated instances so they will not have a unified support to block it.

Years ago (about 8 or 9) I asked a Texas Parks and Wildlife officer about what it would take to get a permit to collect salt water fish from the coast for the pet trade. He said that TP&W frowned upon collecting and selling any wildlife and wanted to put a stop to it. The agenda has been going on for a long time it just now caught up to all of us.
The thing is they consider even captive born to be wild animals. Again the definitions are wide and far reaching. I have to wonder how many people that work for Parks and Wildlife are also members of PETA and or HSUS? They sure do support there agenda.
Working with and captive breeding animals is conservation. It is sad they no longer know this.
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Noah was the first snake collector. ~Eric~

"Due to its recent, and largely simultaneous, recognition as a globally widespread pathogen, chytridiomycosis has been designated an emerging infectious disease (Daszak et al. 2003). Two hypotheses have been advanced to account for the emerging nature of disease caused by Bd; on one hand, the ‘novel pathogen hypothesis’ (NPH) states that Bd has recently spread into new geographic areas, and host species, as a result of the anthropogenically-mediated spread of Bd. On the other hand, the ‘endemic pathogen hypothesis’ (EPH) states that the emergence of chytridiomycosis has been caused by amphibian hosts becoming more susceptible to pre-existing infections as a consequence of changes in the environment.

The purpose of this review is not to weigh up the evidence for the NPH versus the EPH; this was ably undertaken by Rachowicz et al. (2005). Ours, and other, research show that both hypotheses contribute to explaining the current pandemic. The NPH receives support from the fact that epidemic fronts of introduction have been identified (Lips et al. 2006), that globally-recovered isolates of Bd show little genetic diversity suggestive of a recent expansion from a point-origin (Morehouse et al. 2003) and that infected amphibians are detected in the amphibian trade (Mazzoni et al. 2003; Weldon et al. 2004; Garner et al. 2006). The EPH receives support from data showing that Bd was present in global amphibian populations decades ago [USA 1974; Canada 1961; Australia 1978; South Africa 1938 (Rachowicz et al. 2005)] and that there are measurable associations between amphibian condition (Reading 2006), global warming and the onset of chytridiomycosis (Bosch et al. 2006; Pounds et al. 2006)."

Source: www.jcu.edu.au/school/phtm/PHTM/frogs/papers/fisher-2007.pdf

The proposed rule change ignores the Endemic Pathogen Hypothesis (EPH).

Stay Alert - Be Aware!

webwheeler@aqua-terra-vita.com
05/18/2010 12:14 PM

To
susan_jewell@fws.gov
cc

Subject
Injurious Wildlife Evaluation; Amphibian Trade and Chytrid Fungus

I have a few questions that pertain to the following:

"Abstract: We are reviewing a petition to add all traded live amphibians or their eggs to our list of injurious wildlife under the Lacey Act unless certified as free of Batrachochytrium dendrobatidis (chytrid fungus). The importation and introduction of live amphibians infected with chytrid fungus into U.S. natural ecosystems may pose a threat to the interests of U.S. agriculture, fisheries, and commerce, as well as to the welfare and survival of wildlife and wildlife resources. For live amphibians or their eggs infected with chytrid fungus, an injurious wildlife listing would prohibit the importation into, or transportation between, States, the District of Columbia, the Commonwealth of Puerto Rico, or any U.S. territory or possession by any means, without a permit. Permits may be issued for scientific, medical, educational, or zoological purposes."

Source: View Rule

Here are my questions concerning the certification of amphibians to be free of Batrachochytrium dendrobatidis (chytrid fungus):

1. Who qualifies for certification (e.g. the general public, only scientific, medical, educational, or zoological institutions, etc.)

2. Who will perform the certification?

3. How will the certification be conducted?

4. How much will the certification cost?

5. How long will the certification take?

6. How often does the certification have to be done?

7. Where will the certification take place?

I look forward to hearing back from you, and thank you for your time in doing so!

Best regards,
Web Wheeler

REPLY:

Dear Mr. Wheeler:

Thank you for your interest in the chytrid fungus issue. We received a petition from the Defenders of Wildlife that asked us to evaluate their suggestion of listing amphibians in trade as injurious wildlife unless they are certified as being free of chytrid fungus. The petitioners are concerned that trade is a pathway for the fungus, which is devastating amphibian populations. The Defenders petition can be found here: http://www.[url ban]/resources/publications/programs_and_policy/international_conservation/petition_to_interior_secretary_salazar.pdf

We are currently gathering information to address that petition and are not ready to answer questions at this time. We will soon be publishing a notice in the Federal Register that will be asking the public for information on the subject. The Federal Register notice may answer some of your questions. We encourage you to submit information at that time through one of the methods explained in the notice. Your information, along with other public comments, might help us to best address the petition. You can check url=http://www.regulations.gov]Regulations.gov[/url] periodically for Docket No. FWS-R9-FHC-2009-0093.You won't find it until it publishes, but you will have 90 days once it publishes to submit your information online at Regulations.gov. Then we will evaluate all the information submitted and may publish a proposed rule with specific details of what we propose, or make a finding that there is no basis for further action. If we proceed to a proposed rule, there would also be a public comment period. After that, either a final rule would follow, or we could withdraw the proposed rule and take no further action. The process is long, but it greatly benefits from input from the knowledgeable public. During this process, no regulations are expected to change related to the petition.

You might find some useful information on the injurious wildlife
provisions of the Lacey Act from this fact sheet:
www.fws.gov/fisheries/ans/pdf_files/InjuriousWildlifeFactSheet2007.pdf

Again, thank you for your interest in this issue.

Susan Jewell, Injurious Wildlife Listing Coordinator
Fisheries and Habitat Conservation
U.S. Fish and Wildlife Service
4401 N. Fairfax Drive, MS 770
Arlington, VA 22203
phone 703-358-2416 fax 703-358-2487
susan_jewell@fws.gov

P.S. the [url ban] is Defenders of Wildlife.

If it weren't so scary, it would be funny.
Defenders of Wildlife my ass. Defenders of profitable tax exempt witch hunting enterprises.
jsc
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"As hard as I've tried, just can't NOT do this"
John Crickmer

"The sudden appearance of chytridiomycosis, the cause of amphibian deaths and population declines in several continents, suggests that its etiologic agent, the amphibian chytrid Batrachochytrium dendrobatidis, was introduced into the affected regions. However, the origin of this virulent pathogen is unknown. A survey was conducted of 697 archived specimens of 3 species of Xenopus collected from 1879 to 1999 in southern Africa in which the histologic features of the interdigital webbing were analyzed. The earliest case of chytridiomycosis found was in a Xenopus laevis frog in 1938, and overall prevalence was 2.7%. The prevalence showed no significant differences between species, regions, season, or time period. Chytridiomycosis was a stable endemic infection in southern Africa for 23 years before any positive specimen was found outside Africa. We propose that Africa is the origin of the amphibian chytrid and that the international trade in X. laevis that began in the mid-1930s was the means of dissemination."

Source: Origin of the amphibian chytrid fungus

and

"Regarding to adverse effects that contribute to amphibian declines, the effects of atrazine on sex differentiation can negatively affect amphibian populations. The effects of the pesticide mixture on growth can have an even more rapid negative effect on populations, as described above. The immunosuppressive effects are likely even more relevant. Most significantly, the nine-pesticide mixture increased plasma corticosterone levels. Corticosterone can produce all the effects observed with the pesticide mixtures, including retarded growth (Hayes 1995a, 1995b; Hayes and Wu 1995; Hayes et al. 1993, 1997), retarded development (Glennemeier et al. 2002a, 2002b; Hayes 1995a, 1995b, 1997b; Hayes and Wu 1995; Hayes et al. 1993, 1997), and immunosuppression (Belden and Kiesecker 2005; Hayes 1995b). Given these adverse effects and the continued increase and use of pesticides in agriculture over the last 50 years, it is likely that pesticides have played and will continue to play a role in amphibian declines. In particular, the effects described here are very important. Pesticide-induced declines in populations as a result of decreased prey availability and increased susceptibility to predators (as a result of decreased size and the negation or reversal of the relationship between time to metamorphosis and size at metamorphosis) may be difficult to discern in the wild. Perhaps more important, emergent diseases caused by agents such as ranavirus (Brunner et al. 2005; Green and Muths 2005; Jancovich et al. 2005; Pearman et al. 2004) and chytrid (Berger et al. 1998; Green and Muths 2005; McCallum 2005; Ouellet et al. 2005; Rollins-Smith et al. 2002; Weldon et al. 2004) are considered major contributors to amphibian declines. Given the present findings with the flavobacteria in the present study, perhaps these diseases are not emergent at all. As suggested by Burkhart et al. (2003), perhaps what is emergent is the inability to mount proper immune responses as a result of pesticide exposure. As Sparling et al. (2003) pointed out, “Unfortunately, almost all research on amphibian population declines has focused on single factors or multiple factors considered individually with little consideration for interactions.” This approach has to change if problems are to be identified and solutions formulated."

Source: Pesticide Mixtures, Endocrine Disruption, and Amphibian Declines: Are We Underestimating the Impact?

Emphasis in bold is mine.

"In the 1930s, African frogs were exported for use in human pregnancy tests and it is suggested they may have carried a fungal disease with them."

"In the 1930s and 40s, live female Xenopus frogs were used widely in Europe, Australasia and north America in pregnancy testing.

A sample of the woman's urine was injected under the frog's skin; if the woman was pregnant, a hormone in her urine caused the frog to ovulate.

Alternative tests involved male frogs and toads, which produced sperm in response to the human hormone gonadotrophin.

Thousands of Xenopus were exported from Africa each year, potentially carrying Batrachochytrium with them, and - perhaps through occasional escapes - delivering it to the habitats of other continents, where it could inflict major damage on amphibian species that were more vulnerable."

Source: Pregnancy test link to frog fall

Emphasis in bold is mine. To spread the Chytrid Fungus it is not necessary for an actual frog to escape. Untreated waste water from the frog's enclosure can just as easily cause a Chytrid Fungus outbreak in local watersheds. The above evidence strongly suggests that the pet trade was NOT the primary vector for the spread of Chytrid Fungus.