Results 1 to 4 of 4

Thread: Proposed ban - LAST DAY TO STOP

  1. #1
    Founder John's Avatar
    Join Date
    Aug 2008
    Nationality
    [Ireland]
    Location
    United States
    Age
    46
    Posts
    5,963
    Picture Albums: Member Photo Albums

    Exclamation Proposed ban - LAST DAY TO STOP

    Today is the last day to make a comment for or against the proposed regulation (effectively a ban) of the traffic of amphibians between US states. If this moves forward, it will effectively end our hobby to all intents and purposes. The deadline to comment is 11:59 pm Eastern Time US at this address:

    Regulations.gov

    Please make constructive comments. For example, do not make blanket statements such as "this would be bad". Instead, make specific points and please try to cite references (there are plenty of reasons and citations in the threads here and here on dendroboard. Additionally there is a thread going on Caudata.org here).

    Please do make a comment. Aside from the fact that the regulations could all but eliminate our hobby, the groundswell of informed opinion is that the regulations will do little to regulate the real culprits in chytrid spread, and the number of strains and their widespread presence in the wild in the US are points of history - there is no getting that cat back in the bag.

    Lastly, this is another attempt by a very small but "fashionable" lobby group (Defenders of Wildlife) to impose their viewpoint on the American public, curtailing your freedom for their agenda. Even if you support the idea of these regulations, the least you can do is check your facts prior to just signing off on it - the sad fact is that few of the pro-ban folks really have much of a clue about the situation, or are they are pushing their own agenda/reinforcing their own jobs (sadly, reading the comment by its director, this now describes Amphibian Ark, an organization for which I've been a long time donor and supporter).

    PS: I have not posted my own comment yet but I will before the deadline tonight.
    Founder of Frogforum.net (2008) and Caudata.org (2001)

  2. # ADS
    Circuit advertisement
    Join Date
    Always
    Location
    Advertising world
    Age
    2010
    Posts
    Many
     

  3. #2
    Founder John's Avatar
    Join Date
    Aug 2008
    Nationality
    [Ireland]
    Location
    United States
    Age
    46
    Posts
    5,963
    Picture Albums: Member Photo Albums

    Default Re: Proposed ban - LAST DAY TO STOP

    Here is my submission (I've also attached it as a PDF):

    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)

  4. #3
    Founder John's Avatar
    Join Date
    Aug 2008
    Nationality
    [Ireland]
    Location
    United States
    Age
    46
    Posts
    5,963
    Picture Albums: Member Photo Albums

    Default Re: Proposed ban - LAST DAY TO STOP

    By the way, as I write, there are just 6 minutes left to submit your comments so if you haven't done it by now, let us hope we've done enough.
    Founder of Frogforum.net (2008) and Caudata.org (2001)

  5. #4
    Kurt
    Guest

    Default Re: Proposed ban - LAST DAY TO STOP

    I commented months ago. I pretty much said what you did but without all the details. Testing of amphibians for interstate travel is unrealistic and would ever severely restrict commerce or kill it all together in this group of animals. Enforcing such a regulation would be a nightmare for USF&W, as well as the related state agencies.

Thread Information

Users Browsing this Thread

There are currently 1 users browsing this thread. (0 members and 1 guests)

Similar Threads

  1. I need to stop going into pet stores!!!
    By Julia in forum Other Pets
    Replies: 20
    Last Post: May 3rd, 2012, 02:59 PM
  2. Night jumper, won't stop
    By onedge30 in forum African Bullfrogs
    Replies: 14
    Last Post: December 26th, 2010, 01:28 AM
  3. Replies: 4
    Last Post: December 5th, 2010, 03:40 PM
  4. When do they stop growing?
    By zackw419 in forum African Bullfrogs
    Replies: 10
    Last Post: October 14th, 2009, 10:47 PM
  5. Stop the senseless murder of frogs
    By tattooed81 in forum Off-Topic
    Replies: 2
    Last Post: June 10th, 2009, 06:50 PM

Tags for this Thread

Posting Permissions

  • You may not post new threads
  • You may not post replies
  • You may not post attachments
  • You may not edit your posts
  •