PUBLIC COMMENT PERIOD ENDS 1-15-06
We are working to modify this proposal, but need public comments from you to achieve someting reasonable.
PLEASE!! Take a moment and write. You can email using the online public comment form here:
www.state.pa.us/Fish/regcomments
or write to the Executive Director at the address below.
Herp Law Action Alert
The Pennsylvania Fish and Boat Commission has proposed regulations that would:
Ban the importation and breeding of all native species including all subspecies of milk snakes, rat snakes of the Elaphe obsoleta ssp., all North American box turtles, and other reptiles and amphibians commonly bred in captivity.
Reduce the possession limit of native reptiles and amphibians from two to one for common species and zero for 23 species including box turtles, wood turtles, and other species common in captivity without provision for those already held.
And impose numerous other unjustified restrictions, to numerous to elaborate here, on those of us who enjoy interacting with these animals in captivity.
These proposed regulations may be viewed online here:
http://sites.state.pa.us/PA_Exec/Fish_Boat/rulemakings/175nprp.htm
Protect your Rights
When originally proposed, letters and emails from reptile hobbyists and professionals resulted in the formation of a public work group. This group is in the process of attempting to revise the proposal to make it more acceptable.
In the meantime the Commission voted to publish the initial proposal for public comment. It is possible that this will be your only opportunity to express your opposition (or support) for these overly restrictive regulations.
The commission is not bound to accept any recommendations from the work group.
It is very important that we let the Commission know that there are many of us who would be negatively impacted by these regulations. In many cases we will instant become criminals if these regulations take effect as currently proposed.
Please send comments by mail to:
Executive Director
Fish and Boat Commission
P. O. Box 67000
Harrisburg, PA 17106-7000
Or go here and fill out the PAFBC online comment form.
www.state.pa.us/Fish/regcomments
Please take the time to do this. Your ability to interact with native reptiles and many non-native subspecies depends on the action you take today. The public comment period ends 1-15-06.
Sample letter
Douglas Austin
Executive Director
Pennsylvania Fish and Boat Commission
PO Box 67000
Harrisburg, PA 17106-7000
Dear Sir:
I am writing to express my opposition to Proposed Rulemaking 175 regarding native reptiles and amphibians. I understand that there is a public workgroup in the process of developing regulations that will better address the needs of those of us interested in working with these animals in captivity and maintaining them as pets.
I believe the following should be included in the final regulations:
1) The ability to import and export captive produced native reptiles and amphibians.
2) The ability to breed captive produced native reptiles and amphibians.
3)I agree with the total prohibition on the sale of reptiles and amphibians taken from the wild, but believe there should be allowances made for the sale of their progeny if the wild adults are legally held, and proper documentation is available.
4) The legal possession limit for reptiles and amphibians not considered separately in the limits and possession section should remain at two. Reducing it to one is an arbitrary action. The only rationale that I can see for it is to prevent captive breeding. Captive breeding is a valuable conservation tool. There are many indigenous North American species that are no longer collected in significant numbers from the wild because the demand for them is filled by captive produced specimens. Most surrounding states set this limit at four for animals with healthy wild populations.
5) The species being added to the zero take list should not be added arbitrarily. I would like to see some scientific justification for this action in writing before it proceeds.
6) The imposition of a permit requirement for the Northern Copperhead should be eliminated unless there is a scientific basis for it implementation. In my opinion the copperhead remains common throughout its range in Pennsylvania and in the absence of scientific data to the contrary this is an unnecessary and arbitrary action.
7) Sacking contests should continue to be banned in any form at the state permitted rattlesnake hunts. This is a very dangerous activity that does nothing to add to the educational value of these events. On the contrary it sends a terrible message to participants in the hunts about the proper treatment of reptiles as a fellow species. Allowing sacking contests at an event permitted by the Commission amounts to sanctioning this activity.
8) The timber rattlesnake possession limit should be set at one snake per permit with provisions made for reporting and identification on an annual basis for all snakes held.
9) Obvious color morphs should be exempt from regulation, with provisions made to allow the possession of heterozygous and normal individuals produced in captive breeding programs.
10) The regulation of native reptiles and amphibians should be limited to subspecies found in Pennsylvania, not species.
I believe that these provisions should be part of any rewriting of the Pennsylvania reptile and amphibian regulations. Maryland has had a system that addresses these issues in place for several years. It serves to protect wild populations and at the same time allows for captive reproduction and sale of native species. It would serve as an excellent model for Pennsylvania.
Thank you for taking the time to consider my ideas on this matter.
Sincerely,
Fred Bruckman
132 Labrador Dr.
Ligonier, PA 15658
724-593-7341
bruckman@westol.com
