I could see what you're saying about it possibly being bites, as they aren't clustered or really spread over a very wide area and are more sporadic in location. It's hard to call in those photos, because I can't quite see if it's subdermal/subcutaneous such as what bites would cause or if the tissue in the area is raised and inflamed, giving it the red look. Can't tell if the red is from infection or from the tissue under the scales being exposed from bites. That and the overall appearance of his scales along the length of his body, not just those particular areas...doesn't look like he's getting the best care possible, at least judging from those pics. I'm almost wondering if those are open sores from bad sheds, as it looks like he's got quite a bit of dry shed or just super dry skin still on him...not sure that I'd call that scale rot, per se, but not good whatever it is. Sorry I'm not more help, I'll shut up now, lol!