Proposed Ban - LAST DAY!

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

Click to expand...