PIJAC Recommendations on the Ban

This is the full document they sent to me.

FISH AND WILDLIFE SERVICE
SEEKING INFORMATION ON
CERTAIN CONSTRICTOR SNAKES
The Issue.
The United States Fish and Wildlife Service (FWS) is currently reviewing available biological
and economic information and asking for any information from the public on constrictor snakes
from the Python, Boa and Eunectes genera for possible addition of some of these species to the
list of injurious wildlife under the Lacey Act. (NOTE: Even though it published in the
Proposed Rules section of the Federal Register, this is NOT a rulemaking proposal - it is
only a fact finding initiative.)
After reviewing data received, the Service will carefully consider whether further analyses may
be useful for certain species. They will also use this information to help communicate the
potential risks of feral constrictors and expand outreach to prevent the release of unwanted pets.
They might also use the information to work with states that are interested in permitting systems.
What does an injurious wildlife listing mean?
• An injurious wildlife listing prohibits the importation and interstate transport of the
species, gametes, viable eggs and hybrids between States, the District of Columbia, the
Commonwealth of Puerto Rico, or any territory or possession of the U.S. by any means.
• Even if ever listed, an injurious wildlife designation does not prohibit possession, sale,
etc. within a State. (However, a State law may apply.)
• Permits may be granted by the Service for the importation or transportation of specimens
of injurious species and their offspring or eggs for bona fide scientific, medical,
educational, or zoological purposes. The Service will regulate all movement, including
intrastate transportation, of a species for which a permit has been issued.
• If a species was obtained prior to the effective date of a rule, a listing does not prohibit
intrastate transport or possession of species within States, where not prohibited by the
State. Any regulation pertaining to the use of species within States continues to be the
responsibility of each State.
February 11, 2008
(US FWS Snakes)
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The Impact.
In order to determine if further evaluation and stakeholder consultations may be warranted, the
Fish and Wildlife Service published this notice of inquiry to solicit biological, economical and
other data, through public comments, on constrictor snakes from the Python, Boa and Eunectes
genera. Information collected will be used to determine if any snakes within these genera are a
threat, or potential threat, to wildlife, wildlife resources, humans or interests of forestry,
horticulture and agriculture in the U.S. In the long run, if any of these snakes are listed as
injurious wildlife they could not be imported into the U.S. or transported into or between states,
the District of Columbia, Puerto Rico or any territory/possession of the U.S. by any means
without a permit. Permits may be issued only for bona fide scientific, medical, educational or
zoological purposes. (NOTE: Prior to listing, FWS must conduct a science-based biological
analysis and economic analyses and seek additional public comment.)
The FWS is seeking public comments and supporting biological data on the snakes in question.
In an attempt to notify people of the types of information they need, FWS has asked for
comments on the following questions: (NOTE: Responses need not be limited to these
questions, but it would be strategic to address them).
• What regulations does your State have pertaining to the use, transport or production of
Python, Boa and Eunectes genera?
• How many species in the Python, Boa and Eunectes genera are currently in production
for wholesale or retail sale, and in how many and which States?
• How may businesses sell Python, Boa or Eunectes species?
• How many businesses breed Python, Boa or Eunectes species?
• What are the annual sales for Python, Boa or Eunectes species?
• Please provide the number of Python, Boa or Eunectes species, if any, permitted within
each State.
• What would it cost to eradicate Python, Boa or Eunectes individuals or populations, or
similar species, if found?
• What are the costs of implementing propagation, recovery and restoration programs for
native species that are affected by Python, Boa or Eunectes species, or similar snake
species?
• What State-listed species would be impacted by the introduction of Python, Boa or
Eunectes species?
• What species have been impacted, and how, by Python, Boa or Eunectes species?
Recommended Action.
We ask that you withhold submitting your comments until close to the April 30 deadline in order
to allow PIJAC time to provide you with guidance and information that will help you prepare
effective comments. PIJAC is currently engaging in meetings with the FWS and gathering
information to assist you on this issue. Again, please note, that this is not a proposed rulemaking
notice – it is only a notice to gather information, especially biological, on these particular snakes.
PIJAC is also undertaking an extensive literature search of peer-reviewed articles, lay magazines,
and books to gather relevant information to respond to the questions raised by the FWS. Anyone
who has copies of articles or other pertinent information on the biology of any of the species
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should send them to PIJAC at info@pijac.org AND to PIJAC’s Senior Science and Policy
Advisor, Dr. Jamie K. Reaser:pijacscience@nelsoncable.com. Dr. Reaser is compiling a
database which PIJAC will use to develop a formal science-based response on behalf of the
industry and hobbyists, as well as to provide guidance for people to use in crafting their
comments.
Thirdly, PIJAC is conducting a survey of concerned members of the herpetoculture community
and the industry to collect data to answer the questions posed by the FWS regarding numbers of
breeders, animals sold, economic questions, etc. This information will be consolidated and
presented as data summaries without identifying individuals supplying the information. The
FWS is very aware of the concerns of many people about revealing their identity. If you are
interested in providing herpetoculture data to PIJAC, please contact PIJAC at info@pijac.org.
All proprietary data (i.e. contributors’ identity, numbers of animals, financial data) will be
treated as confidential information and will only be seen by PIJAC staff.
We urge you to review this notice carefully and consider the implications that could come as a
result of listing any of these snakes as injurious wildlife. If you have further questions
concerning this matter, please contact PIJAC’s Marshall Meyers by phone at 202-452-1525 or by
email at mmeyers@pijac.org. Those who are not members of PIJAC and desire further
information about membership may phone Nancy Knutson at 1-800-553-PETS (7387) or visit
the PIJAC website at www.pijac.org.
Where to send your comments:
FWS will be receiving comments and other information on this issue until April 30, 2008. You
may submit comments by one of the following methods:
• U.S. mail or hand-delivery: Public Comments Processing, Attn: RIN 1018-AV68,
Division of Policy and Directives Management, U.S. Fish and Wildlife Service, 4401
North Fairfax Drive, Suite 222, Arlington, VA 22203; or
• Website: www.regulations.gov (Follow instructions for submitting comments. In the
“comments or submissions” box type in keyword: “injurious wildlife”. This should take
you to the comment page.).
FWS will not accept e-mail or faxes, and will post all comments on http://www.regulations.gov.
This generally means that FWS will post any personal information you provide. For further
information contact Erin Williams, Branch of Invasive Species at (703) 358-2034 or
erin_williams@fws.gov.
Not Yet a PIJAC Member?
For more than thirty-five years, the Pet Industry Joint Advisory Council (PIJAC) has ensured the
prosperity of the pet industry. To learn more about PIJAC, please visit our website at
www.pijac.org. For further information on Membership, please send an e-mail to
members@pijac.org or phone 1-800-553-PETS (1-800-553-7387).
Our Business IS Your Business. PIJAC: Keeping You in Business.

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PIJAC Recommendations on the Ban