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the latest on the fwc
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by thenovice on August 27, 2006
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this is a summary of the fwc meeting in tampa:
Marcus Cantos
19235 Miami Blvd.
Fort Myers, Florida 33912
Phone: (239) 470 - 7630 Fax:(239) 267 -6715
Florida Fish and Wildlife August 25th, 2006
Conservation Commission
620 South Meridian Street,
Tallahassee, Florida 32399 - 1600
Dear Captains Harrison, West and All:
I want to thank you for conducting your public work shops concerning the Commission's proposed captive wildlife regulations. Even with the short time constraints that we, and you, are under, I believe that you were able to see that many Florida Reptile Industry/Hobbiest members are very concerned about the impacts and effects that the proposed changes will have on our hobby and our industry as they are now written. As an Industry member for the past 17 years and an elected industry representative, I respectfully submit the following comments and recommendations that I hope will help you to develop final rules that will help the Commission and the Reptile Industry:
1) I wish to support and echo the verbal comments submitted to the Commission by Curt Harbsmeyer, Eugene Bissette, Mike Cole and Lisa Welch at the workshop held in Tampa on August 22nd.
2) Regarding the many, many scientifically and logistically unfeasible aspects of pit tagging venomous and reptiles of concern that the Commission has herd at these workshops: The science is not yet at a point where younger animals could be successfully tagged, or, where the many different systems that many keepers are already heavily invested in could be universally read. Also given the legal questions that arise from either bites from, or deaths of animals that would not normally be tagged; or from a diminished antivenin supply that will result from the undue burdens placed upon venom suppliers, the service needs to develop a digital photograph ID protocol that corresponds to each species needing identification.
3) In regard to the listing of "giant snakes" as reptiles of concern:
Considering the severe impact on the hobby, and enormous financial burden placed upon the industry by the listing of Reticulated and Burmese Pythons (Python reticulatus and Python molurus) - and further considering that as of current statistical data, it is scientifically 100% safe to grant exceptions to the more expensive color morphs of both species, as neither can be expected to reproduce in the wild, and, also, considering the very low, almost imperceptible, incidences of escape of the color morphs and more easily accomplished recapture; and that by granting an exception for color morphs of Burmese and Reticulated pythons, 80 - 90% of the large finical burden the industry will be forced to bear will be eliminated, the Commission would be prudent to make the color morph exception - or at very least explain why it chooses not to.
4) The Commission is seeking to list the Asian Water Monitor (Varanus salvator.) The Commission has not demonstrated any evidence of this species being an invasive threat, or even any incidence of escape. Other states have listed this species as possibly dangerous when at it's very largest. This is a knee jerk reaction to a theoretical threat. In captivity, it is an accomplishment for an advanced keeper to grow this species to a size capable of causing harm to even a child. Like other lizards, at such a large size in captivity, the monitors are almost always quite tame and lethargically obese. In the wild, in Florida, the Asian Water Monitor will contract a cold virus and perish after only a few nights of temperatures below 60 degrees F. This species comes from a tropical climate, more consistently warmer than Florida's sub - tropical climate; and cannot withstand our cooler months. This listing will significantly impact Florida's importers and is, for the most part, a cosmetic effort to do what the other states are doing - for a species that will spend most of it's time near the bottom of Florida's food chain if released.
5) The Commission is also seeking to list Tegu lizards (the Genus Tupinambus) another species that will spend most of it's life near the bottom of Florida's food chain in the wild. This effort is in response to 17 confirmed sightings of at least 4 different sizes of Tegu in Polk County. It is entirely possible that 4 different animals have been sighted a total of 17 times. The Commission has yet to endeavor to catch and remove these animals. I have personally hunted the Tegus in the Paraguayan Chaco with the native Indians. I have seen that Tegu capture is not a difficult task when experienced hunters work at it. The Commission has not tried to predict even the potential for impact this Genus could have on Florida's ecosystem or even verified that the 4 - 17 animals in Polk County are a sustaining population - or are simply 4 - 17 animals released by a keeper - or even by an individual who simply wanted to see them listed. What a large door that may be opening to the small minority of anti - exotic animal rights activists in our state, several of whom have already made their extremist positions clear at these work shops, and who have already shown their willingness to do far more to accomplish far less.
Neither Scott Hardin's nor Kevin Engee's invasive species presentations included Tegus as reptiles of concern. This species seems to have been added in the 11th hour, without any real history of supporting scientific evidence, and is a prime example of how a listing process without specific protocols and defined criteria could easily be misused or abused.
6) The Commission is attempting to list 8 different species of reptiles as Reptiles of Concern without there being any constant standard for the listing. This listing will have serious impact upon the reptile hobby and the reptile industry. With in this initial listing is already at least one prime example of a species "heaped on the pile for good measure" without any scientific evidence, or even pressure brought on by the sensationalizing media. In short, Tegus were for the most added as an after thought. "After thoughts" or "targets" of animal rights groups cannot be part of such an important, scientific, public serving process.
I recommend that the Commission form a working group, including industry members, to develop, determine, establish and promulgate a specific set of standards to consider and review a species before adding it to this important list that will affect so many Floridians in so many ways.
This process should at very least include: The establishment of a set of criteria or standards for considering inclusion. It should consider and rate: environmental impacts of the species, threat to people, pets and or live stock, likely hood of sustaining an invasive population, history of the species in captivity, impact of previous releases - if any, and likely hood of releases.
With out the establishment of a specific, well planned set of protocols for considering and adding animals to a list of restricted reptiles, species can be added arbitrarily; and the entire process can become a tool of trade restraint, easily manipulated by outside parties - such as animal rights activists who will quickly figure out that if they simply buy a dozen of any reptile and dump them in the right place they can close a species off to the public and the industry.
Finally, with reptiles in the spotlight of a sensationalizing media more interested in selling add space than getting the facts straight, the Florida Reptile Industry and the Fish and Wildlife Conservation Commission are in the same boat on many, many issues. A black eye for you is almost always one for us too and we are constantly working harder to keep reptiles and amphibians in the proper public perspective. I implore the Commission to be prudent in it's efforts to regulate, as over regulation will cause enforceability problems and will result in the Commission's loosing credibility. I hope that our industry can work more closely with the Commission to accomplish these goals that are important to all Floridians. In light of the many important comments received during this process, I recommend that the Commission hold another set of workshops, after considering public comments, before promulgating it's final rules.
Thank you for considering my comments. I am looking forward to hearing the report of all received public comments to the Commission at the Commission meeting in St. Petersburg in two weeks.
Sincerely,
Marcus Cantos
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