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Thread: USFWS ban on amphibians date soon!

  1. #1
    Founder John's Avatar
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    Exclamation USFWS ban on amphibians date soon!

    This is a reminder that there are only 11 days left to leave a comment on the Federal Register about the proposed ban on the trade/shipping/moving of amphibians over borders between US states by anyone except licensed institutions, etc (that means everyone in the amphibian hobby will no longer be able to ship, bring, or otherwise move their frogs, toads, newts, salamanders, etc, over state borders).

    If you don't do this, it could mean an end to the amphibian keeping hobby.

    Here is my advice for leaving a comment. I encourage you to do your own internet research if you are not familiar with the topic Chytrid fungus (also called B.d.). But here is my advice to you when writing your comment.

    Firstly, be polite and civil. Coming across as an angry and unreasonable individual will not help your comment to be taken seriously. When making a comment, back it up with some facts. A comment such as "The ban shouldn't happen because it is a bad idea" does not tell anyone why it is bad and this comment won't be taken seriously by USFWS. So here is what I would do:


    • Make it clear that you live in the USA, unlike many of the current commentators (who have no right to decide US policy).
    • You should outline an opinion regarding the proposed legislation with questions like these in mind:
    • Will it be of any benefit to native amphibians? The "pro-ban" people say yes, but the simple fact of the matter is that chytrid is everywhere in the US right now. A ban like this, at this stage, will give virtually no benefit, if any, to our native amphibians who have already suffered the lion's share of the losses they are likely to suffer, and will cost us a lot of our tax dollars.
    • Does the pet trade really contribute to the spread of chytrid, at this point in time? Most amphibian experts will tell you that the majority of the disease's spread is due to the bait fishing industry and the amphibians as food industry. Bait fishermen use tiger salamander tadpoles to fish for bass. These tadpoles are often infected with chytrid from other parts of the country and when they are used as bait they introduce chytrid to that water source. The fisherman also have a bad habit of letting their bait go at the end of the day. The frog legs/amphibian as food industry is largely responsible for the spread of the American Bullfrog, which is very tolerant of chytrid, making it a great carrier of the disease. Waste water from these frog rearing facilities can carry chytrid. So when it comes down to it, the pet trade and pet owners don't even figure in the equation when it comes to chytrid spread.
    • The vast majority of chytrid in the amphibian pet trade comes from the whole salers importing frogs from foreign countries. Instead of making a ban on interstate amphibian trade, shouldn't the USFWS be inspecting and testing amphibian imports when they first reach the US? Why do hobbyists have to be punished instead of big businesses?
    • When it comes down to it, bearing in mind what I've pointed out earlier, the only real effect that this ban will have is to reduce your freedom as American citizens. This is quite literally another threat to your 4th Amendment rights as citizens of the United States of America.
    • The ban will likely only effect you as a hobbyist, and the people you know in the hobby, because we are the ones who will have to pay big money to bring or send our frogs over state lines. Companies will just factor it into their prices on frogs and salamanders, etc, passing the cost on to you, and preventing you from ever being able to sell captive bred offspring beyond your local state. Also bear in mind that the ban will cover taking your frogs with you if you move to an out of state home, or you go off to college and want to take your pet with you!

    Even if you are not a citizen, if you are paying taxes in the US I think you should voice your opinion. It's a sad fact that most of the comments on the register right now are from foreigners who don't even live in the United States. Let's point that out as much as we can while making reasonable, fact-based arguments against this ban on trade between states of amphibians by ordinary people.

    Please do comment. Your hobby may disappear if you don't.

    Deadline
    The USFWS will consider information received or postmarked on or before December 16, 2010.

    Submit
    You may submit comments by one of the following methods.

    Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments to Docket No. FWS-R9-FHC-2009-0093.

    U.S. mail or hand-delivery: Public Comments Processing, Attn: Docket No. FWS-R9-FHC-2009-0093, Division of Policy and Directives Management, U.S. Fish and Wildlife Service, 4401 North Fairfax Drive, Suite 222, Arlington, VA 22203.

    Additional Information Contact
    Susan Jewell, Branch of Aquatic Invasive Species, U.S. Fish and Wildlife Service, MS 770, 4401 N. Fairfax Drive, Arlington, VA 22203; telephone 703-358-2416. If you use a telecommunications device for the deaf (TDD), call the Federal Information Relay Service (FIRS) at 800-877-8339.

    Your comments must be received by December 16th!
    Founder of Frogforum.net (2008) and Caudata.org (2001)

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  3. #2
    onedge30
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    Default Re: USFWS ban on amphibians date soon!

    Thanks John for keeping us posted on current issues affecting our lives.

    I posted a comment:

    To USFWS,

    Please sincerely take the time to consider who this 'ban' would hurt the most. As proposed, that would be the retail and hobbyist who keep amphibians. I am a US citizen and want the right to keep and purchase amphibians in the US. 1) Chytrid fungus is already out in the wild. To prevent the greatest exposure to further spread stop it before it gets to the US. Inspect all incoming shipments of amphibians from outside the country. Don't ban interstate trade. 2) Target the greatest exposure threat first. The commercial bait fish industry and the amphibian food industry. Not the smaller retailer and hobbyist.

    Sincerely,

    Jeff Kapp
    Orlando, FL
    USA

  4. #3
    Founder John's Avatar
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    Default Re: USFWS ban on amphibians date soon!

    Thanks Jeff.
    Founder of Frogforum.net (2008) and Caudata.org (2001)

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    Default Re: USFWS ban on amphibians date soon!

    Regulations.gov

    Here is the place to place your opinion.. Every vote counts.. Do
    it.. Do it know Come on.. Kill this.............
    Michael Novy
    rainforestjunkys.com

  6. #5
    Moderator tgampper's Avatar
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    Default Re: USFWS ban on amphibians date soon!

    I have notified everyone in the Nebraska Herpetological Society and many have responded! Please kill this...

    I received an email from Save the Frogs yesterday asking everyone to support the USF&WS and ban amphibian keeping because of the chytrid problem. Looks like there is some stiff competition, so please write and support our right to keep amphibians
    Terry Gampper
    Nebraska Herpetological Society




    “If we can discover the meaning in the trilling of a frog, perhaps we may understand why it is for us not merely noise but a song of poetry and emotion.”
    ---
    Adrian Forsyth

  7. #6
    onedge30
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    Default Re: USFWS ban on amphibians date soon!

    I see the Save the Frogs notice. Listing all the causes with 'pet' hobby first, and all the 'likely to' and 'absolutely inevitable' chain of events. Very sad.

    With all these possible bans and proposed testing, I feel overwhelmed as an individual to be able to actually do anything to change the course of these actions.

  8. #7
    Founder John's Avatar
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    Default Re: USFWS ban on amphibians date soon!

    Savethefrog's is a man called Kerry Kriger. He's Australian - I don't even think he's a US citizen. I am still working on my comment but you can bet I'll mention Savethefrog's and their agenda (which is to make Kerry famous, not save frogs).
    Founder of Frogforum.net (2008) and Caudata.org (2001)

  9. #8
    Viv
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    Default Re: USFWS ban on amphibians date soon!

    Well, I posted my opinion today and I think the ban is totally useless at this point, the fungus has already spread throughout the USA. And I am sure that amphibins do not follow USA laws, they can walk across borders at any time! I like the idea, but not an effective way to solve it. They should be watching the bait industry and amphibian food industry!

    Alex

  10. #9
    Founder John's Avatar
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    Default Re: USFWS ban on amphibians date soon!

    Here's what I sent them today:

    From: John P. Clare, Founder of Caudata.org.
    To: USFWS
    Subject: Proposed rules “Injurious Wildlife Species: Petition To List All Live Amphibians in Trade as Injurious Unless Free of Batrachochytrium dendrobatidis (Document ID FWS-R9-FHC-2009-0093-0001)”.

    Dear Sir or Madam:

    I am writing on behalf of the members of Caudata.org. We are hobbyists maintaining and breeding amphibians in captivity, predominantly as pets. We have also funded grants for amphibian conservation research around the world in partnership with Amphibian Ark.

    - The origins of Batrachochytrium dendrobatidis are currently uncertain. There is evidence that the disease may be native to or long established in the United States (James et al. (2009) PLos Pathogens 5: p. e1000458 and Longcore et al. (2007) J. of Wildlife Management 71:435-444). Since its discovery in the late 1990s, several theories have been presented as to its origin but it is certainly not unreasonable to suggest the disease may have had some presence in the US in the long term, as evidenced in the above reference.

    - Bd can persist in water without a host for long periods of time. A CDC study has shown that the zoospores can remain infectious in lake water for at least 7 weeks: CDC - Survival of Batrachochytrium dendrobatidis in Water: Quarantine and Disease Control Implications and studies have shown that Bd can survive in nutrient rich liquids for 4 months or more: Isolation of Batrachochytrium dendrobatidis.

    - Therefore, Bd can be spread by water and moist soil. Freshwater fish and their water, as well as aquatic and terrestrial plants with soil are vectors for the spread of this pathogen. The industries surrounding both fish/aquaculture and plants dwarf the inter-state trade in amphibians. Reference for vectors of the disease: Johnson M. L. ,Speare R. (2005) Dis. Aquat. Org 65:181–186, also Pieter T. J. Johnson, PNAS February 28, 2006 vol. 103 no. 9 3011-3012.

    - Bd is found throughout the continental US – for example, Hossack et al. Journal of Wildlife Diseases, 45(4), 2009, pp. 1198–1202. Realistically, we cannot legislate to change history. Therefore, an expensive and impractical regulation of inter-state movement of amphibians will not result in reduced presence of the disease.

    - Bd is so widespread in the US and so readily spread that US Department of Agriculture has determined the disease “non-actionable”.

    - An October 2010 study by Tree Walkers International - chytrid study | Tree Walkers International - found that, from test samples from frog hobbyist collections (i.e. frogs as pets) across the US, only 2 frogs out of 273 tested positive for Bd – just 0.7%. This is a realistic representation of the captive amphibian hobby. Contrast this number to the much higher incidence determined by Picco and Collins (Conserv Biol. 2008 Dec;22(6):1582-9) for amphibian larvae used by the Bait Fishing Industry. Picco and Collins also found that 26-67% of US anglers utilizing bait amphibians released their excess bait into waterways, as did 4% of bait shops. This has been occurring for decades.

    - As the Defenders of Wildlife themselves point out (Gratwicke et al. 2010, Frontiers in Ecology and the Environment 8: 438–442), we must surely consider the food amphibian industry (i.e. frogs farmed for consumption as food by humans) as a significant cause of Bd spread. The US imported 75% of all frog legs traded internationally. It would seem that USFWS efforts would be better spent testing amphibian imports at the port of entry into the US, rather than regulating inter-state trade.

    - From these numbers, decimating the amphibian pet industry and the ability of hobbyists to keep and share these animals, and the knock-on effects on businesses that subsist on the sale of products to that industry and hobbyists (e.g. cricket farms), will not impact the spread of Bd and other amphibian disease and will, simply put, cost the taxpayer an exorbitant amount of money and infringe on the rights of law-abiding American citizens to keep pets and run businesses that have little or no blame in the spread of this disease.

    - The USFWS says "The Service is in no way attempting to curtail the trade in amphibians". Testing facilities for Bd are few and far between, and are not generally accessible to the general public. In fact, the OIE, the world authority on animal diseases, has yet to even validate and approve a standard method for Bd testing. Should these regulations come into effect, they would effectively end the keeping and breeding of amphibians outside scientific institutions.

    - I, and many other scientists, had my first real scientific experience as a child watching the development of tadpoles. It is very disheartening to think that the availability of such learning experiences will be curtailed or eliminated all together for ordinary people.

    Therefore I ask that you do not regulate inter-state transport of amphibians as proposed. If anything, our taxes are better spent on the testing of amphibians and amphibian products coming into this country from outside the US at the port of entry.

    Regards,

    John P. Clare, Ph.D.
    Founder of Caudata.org
    Founder of Frogforum.net (2008) and Caudata.org (2001)

  11. #10
    Jeff Kennedy
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    Default Re: USFWS ban on amphibians date soon!

    Well done John...well done

  12. #11
    Kurt
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    Default Re: USFWS ban on amphibians date soon!

    That's basically what I said but without so many details. Kudos to John.

    PS Are you sure Kerry Krieger is Australian? I met him and he doesn't have an Australian accent.

  13. #12
    Founder John's Avatar
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    Default Re: USFWS ban on amphibians date soon!

    He sure is. You met me, do I have a noticeable Irish accent?
    Founder of Frogforum.net (2008) and Caudata.org (2001)

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