PUBLIC SUBMISSION | As of: February 16, 2009 Tracking No. 8053e977 Comments Due: April 30, 2008 |
Docket: FWS-R9-FHC-2008-0015
Injurious Wildlife Species; Review of Information Concerning Constrictor Snakes from Python, Boa, and Eunectes genera
Comment On: FWS-R9-FHC-2008-0015-0001
Injurious Wildlife Species; Review of Information Concerning Constrictor Snakes From Python, Boa, and Eunectes genera
Document: FWS-R9-FHC-2008-0015-1314
Comment on FR Doc # E8-01770
Tempe, AZ, 85282
April 30, 2008
Regarding public comments for the proposed rule titled Injurious Wildlife Species;
Review of Information Concerning Constrictor Snakes From Python, Boa, and
Eunectes genera
To Whom It May Concern,
I respectfully request your consideration of my responses to your questions below.
Regarding question (1) What regulations does your State have pertaining to the
use, transport, or production of Python, Boa and Eunectes genera?
Our state (Arizona) has well-qualified and capable biologists who have a great
understanding of our state’s diverse climatic and geological zones. They have
identified restricted live wildlife per AZ Revised Statutes, Section R12-4-406 which
describes wildlife that may be considered injurious or potentially injurious to
wildlife and wildlife resources, to human beings, and to the interests of forestry,
horticulture, or agriculture in our state. These statutes include references to
applicable statutes regarding importing, exporting, transporting and possession of
said wildlife. These regulations do include potentially injurious reptiles including:
The family Elapidae. Common names include: cobras, mambas, coral snakes,
kraits, and Australian elapids; The family Hydrophiidae. Common name: sea
snakes; The family Viperidae. Common names include: true vipers and pit vipers,
including rattlesnakes; The family Atractaspidae. Common name: burrowing asps;
and The following species and genera of the family Colubridae: Dispholidus typus.
Common name: boomslang; Thelotornis kirtlandii. Common names include: bird
snake or twig snake. These regulations also include various turtle, tortoise, lizard,
and crocodilian species that may be prohibited due to their protected and / or
endangered status.
These regulations do NOT include Python, Boa or Eunectes species commonly
kept as exotic pets or display animals because the biologists and regulatory
agencies within out state understand that they are not injurious or invasive species
in our area, and do not have the potential to become injurious or invasive species
in our area.
Regarding question (2) How many species in the Python, Boa and Eunectes
genera are currently in production for wholesale or retailsale, and in how many and
which States?
I would refer you to PIJAC representatives whose members could best describe
the diversity of species being produced in captive collections for wholesale or retail
trade. Personally, I produce and market two species of snakes: Python regius and
python anchietae which are sold throughout the 48 contiguous states.
Regarding question (3) How many businesses sell Python, Boa or Eunectes
species?
This will be a difficult number to tabulate. It was my experience while establishing
my snake breeding business that federal and state tax and regulatory agencies to
not provide business classification systems that adequately identify this type of
activity. My business description in Arizona is that of retail pet store. I do not sell
dog treats and kitty litter. I breed snakes and sell them primarily to other breeders
and enthusiasts. But, given the limited classification system available, retail pet
store was the best description of my business activity. A business actively
involved in buying and selling of such animals, and not breeding them would likely
have the same issues regarding business classification making it difficult to
tabulate the number of businesses involved in this trade.
Regarding question (4) How many businesses breed Python, Boa or Eunectes
species?
I will restate some of my comments from question (3): This data will be difficult to
tabulate. It was my experience while establishing my snake breeding business
that federal and state tax and regulatory agencies to not provide business
classification systems that adequately identify this type of activity. My business
description in Arizona is that of retail pet store. I breed snakes and sell them
primarily to other breeders and enthusiasts throughout the 48 contiguous states.
But, given the limited classification system available, retail pet store was the best
description of my business activity.
Regarding question (5) What are the annual sales for Python, Boa or Eunectes
species?
Again, the inability to properly classify businesses involved in this trade will make
this data very hard to extract. From a personal prospective, the ability to freely
market the animals I produce throughout the 48 contiguous states is vital to my
business and my family income. In 2007, my annual sales of pythons totaled
$17,000 as reported to the IRS. Although this may be considered a hobby-
business, any acts to negatively impact these interstate sales will have a
devastating impact on my business, a substantial negative effect on my family’s
income stream, and a negative impact to the businesses who provide the supplies
and services I use to operate this business.
Regarding question (6) Please provide the number of Python, Boa or Eunectes
species, if any, permitted within each State.
I am not aware of any Python, Boa or Eunectes species commonly kept as exotic
pets or display animals that are restricted in Arizona.
Regarding question (7) What would it cost to eradicate Python, Boa or Eunectes
individuals or populations, or similar species, if found?
When individual states properly regulate the wildlife laws to account for the
specific risks inherent to their range of climatic and geological zones, there is no
cost to eradicate these species.
Regarding question (8) 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?
The situation of introduced Python and Boa species in Florida should be well-
enough understood by now to estimate these numbers. South Florida represents
a climatic and geological zone that is unique to the contiguous Unites States and
the costs associated with recovery in that area will provide the cost data for the
entire U.S. as Florida represents the only part of the contiguous United States
where this is likely to occur.
Regarding question (9) What State-listed species would be impacted by the
introduction of Python, Boa or Eunectes species?
It is highly unlikely that any imported Python, Boa or Eunectes species can
survive in Arizona in order for them to have an impact on any state-listed species
here.
Regarding question (10) What species have been impacted, and how, by Python,
Boa or Eunectes species?
To my knowledge, no species in Arizona has been impacted by Python, Boa or
Eunectes species.
Thank you for your consideration of my comments.
Sincerely,
Paul Fisher