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Why are you avoiding the simple, direct questions? Again I ask the following:

Do you support the right of private citizens to maintain amphibian collections? Yes or no?

Is it better to have only pictures of Agalychnis annae instead of the population thriving under the care of myself and other dedicated hobbyists? Yes or no?

Should Atelopus zeteki have been left to perish in the wild instead of being moved to captive breeding facilities? Yes or no?

Is it really better that Bufo periglenes went extinct instead of being established in the hands of zoos and hobbyists? Yes or no?

If you answer yes to any of the last three, how do you justify calling yourself a conservationist?
Tony,
Within the past decade the U.S. alone has imported 221,960 Agalychnis frogs according to the Species Survival Network (SSN). I was wondering if you knew that. It does not seem to have helped the species.

As for golden toads and golden frogs, of course it would be great to have captive populations of them, but the important question is why are they extinct/nearly extinct? My answer is the spread of chytrid fungus. Is it better to tackle the symptom or obviate the cause? The latter I say.

As for "Do you support the right of private citizens to maintain amphibian collections? Yes or no?":
As you noticed on my Travel page that was linked to by somebody in this thread, I have traveled all around the world. Those travels shaped who I am, and constituted some of the best times of my life. I would therefore be a hypocrite if I did not support freedom for all sentient beings.

"All you touch and all you see is all your life will ever be." --Pink Floyd

Now I return to saving the frogs, and I hope you will too. Remember: the future of amphibious life on this planet lies in your hands and in your actions.
Bye,
Kerry
 

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My answer is the spread of chytrid fungus. Is it better to tackle the symptom or obviate the cause? The latter I say.
So what is your plan to eliminate chytrid fungus where it has been introduced?

As for "Do you support the right of private citizens to maintain amphibian collections? Yes or no?":
As you noticed on my Travel page that was linked to by somebody in this thread, I have traveled all around the world. Those travels shaped who I am, and constituted some of the best times of my life. I would therefore be a hypocrite if I did not support freedom for all sentient beings.
Nice evasion. Yes or no?
 

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As for "Do you support the right of private citizens to maintain amphibian collections? Yes or no?":
As you noticed on my Travel page that was linked to by somebody in this thread, I have traveled all around the world. Those travels shaped who I am, and constituted some of the best times of my life. I would therefore be a hypocrite if I did not support freedom for all sentient beings.
Oh, okay. Animals should be completely free from human bondage. Total animal liberation is your end goal, anything else would make you hypocrite.

When you were traveling around the globe, what was your decontamination proceedure before and after visiting different countries? In other words, how much chytrid have you personally spread? What's your chytrid footprint? How can you be sure?

Although no one wants to talk about it, humans and scientists specifically seem tome to be the most likely vector for this pathogen. Occam's razor seems to apply quite well. Much like the media or congressional pay raises, quis custodiet ipsos custodes?
 

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To bring this back to the op, I personally don't feel it's bad to ask froggers who want to ship/bring frogs across state lines to send swabs to a lab that can do pcr's and have that lab issue a Bd free certificate on an annual basis.

I understand that this could go horribly wrong (name 5 things that the Feds do better than the private sector) but that's what the comment period is for. It's better for us to make suggestions as we know what goes on than to sit idly by and have stuff happen to us.

We should discuss a framework for how testing and certification could realistically work.
 

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As for "Do you support the right of private citizens to maintain amphibian collections? Yes or no?":
As you noticed on my Travel page that was linked to by somebody in this thread, I have traveled all around the world. Those travels shaped who I am, and constituted some of the best times of my life. I would therefore be a hypocrite if I did not support freedom for all sentient beings.
I read this as you do NOT support the right of private citizens to maintain amphibian collections. Is this an accurate statement?
If this is the case, why do you come onto a forum dedicated to the care and breeding of captive (IE owned by private citizens) frogs, seeking help/donations?
 

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Discussion Starter #89
While reading some of the comments on the proposed USF&WS listing, I've come across some disturbing news re. PCR testing for DB which I'm going to post on a new thread.

I suggest having a look a the comments once in a while. This can be done by visiting Regulations.gov and searching on FWS-R9-FHC-2009-0093.
 

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Has anyone else noticed that quite a few of the supporting comments are from people that are not even US citizens? Something seems a little off there. What business do people who admit they are from China, Australia, and who knows where else have in influencing US law? Incidentally, I hope everyone who apposes this leaves a comment. So far it looks like the comments are around ten to one supporting it.
 

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Discussion Starter #91 (Edited)
Has anyone else noticed that quite a few of the supporting comments are from people that are not even US citizens? Something seems a little off there. What business do people who admit they are from China, Australia, and who knows where else have in influencing US law? Incidentally, I hope everyone who apposes this leaves a comment. So far it looks like the comments are around ten to one supporting it.
I'm a U.S. citizen living in Canada. I have, and perhaps again in the future would like to purchase frogs from private breeders in the U.S., so this legislation affects me, as well as those who are not U.S. citizens living in other countries.

Since the U.S. economy is rather fragile right now and since the U.S. has the greatest trade deficit in the world, continued trade exports to foreign countries may hold some weight in this issue. And, in my opinion, you need all the help you can get to oppose this legislation.

P.S. Mark Pepper of Understory Enterprises (UE) is also in located in Canada and doing business in SA. This USF&WS proposal very likely would have a negative affect on your ability to purchase and import frogs from UE as well.
 

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I am also curious why everyone needs an EXOTIC amphibian. What is wrong with the treefrog that lives down the street from you? It's not cool enough? Could you sacrifice a bit of coolness for the good feeling that comes from the knowledge that your pet is not going to cause local populations to go extinct when it escapes, establishes a population, spreads its diseases and eats native frog populations?
Does this post advocate the removal of local amphibians to be kept as captives for personal enjoyment? Seems incongruent to your agenda.
I also have no concerns about my darts escaping my home, becoming established, and eating all the local amphibians. Disease is obviously the primary concern of this thread, and I couldn't give an absolute guarantee that none of the animals in my collection would spread disease within in the few minutes they would be able to survive outdoors. However, myself and many of the more conscientious keepers/breeders spend hundreds, if not thousands annually on myriad testing and treatment of our collections to ensure that even in captivity, they will not spread novel or natural diseases among themselves.
 

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Hi Web Wheeler,
I am not sure what damage you speak of. That article is a pretty infrequently cited paper everywhere but on these types of forums. As for my reception on this forum, do you really think I post here to win your hearts? You guys have bashed me for 2 years. You all scrounge for any possible bad thing you can say about me. And few of you have ever demonstrated to me that you are willing to do what YOU need to do to SAVE THE FROGS! As if your actions could not possibly affect frogs; and as if all the little kids and their parents who buy frogs would never let them free into the wild. "Oh but they are not the RESPONSIBLE pet owners!" you say. Give me a break. They are your clients and they are uneducated and they will let frogs loose. END OF STORY. And the store manager at Brookstone selling his Frog-o-Sphere will dump the water down the toilet when the little African Clawed Frog dies in its handheld tank. And that water will go out into the environment. And until you prove that none of that happens, then suck it up, get your frogs tested, prove them chytrid-free and pass that cost along to the consumer along with an educational card explaining the cost, why it exists, and what they as consumers need to do to secure the future of wild amphibians.

Your concern appears to be your hobby or your financial income. My concern is saving frogs. If you love me great, if you hate me, I'm sorry you feel that way. So as for a repudiation of past statements, it seems odd that you would expect one of me without you having put forth reasons to dispute the basic tenet of the paper in question (or the Reply To Garner that I wrote, also visible on MY PUBLICATIONS PAGE ). That basic tenet being that the intercontinental trade and transport of amphibians is responsible for the spread of harmful infectious diseases, a viewpoint held by the overwhelming majority of amphibian and disease biologists.

I am also curious why everyone needs an EXOTIC amphibian. What is wrong with the treefrog that lives down the street from you? It's not cool enough? Could you sacrifice a bit of coolness for the good feeling that comes from the knowledge that your pet is not going to cause local populations to go extinct when it escapes, establishes a population, spreads its diseases and eats native frog populations?

Regarding the pet trade, my main concerns are disease spread, and taking amphibians from the wild.
The former has received ample discussion here already. As for the latter:
(1) It is thoroughly unethical to take an amphibian from its home in the wild and sever its ability to return to its home;
(2) Those wild-caught amphibian vendors are your financial competition. It seems as if you would rejoice in regulations that would limit their ability to import their amphibians.
If you think it is cool to take frogs from the wild, that is your right to think that, but it would be contradictory to say you love frogs.

Finally, since everyone here knows a lot about frogs, I would like to invite every person on this forum to give a free talk to the public about the importance of protecting frogs this coming SAVE THE FROGS DAY April 29th, 2011.
Save The Frogs Day | April 29, 2011

Have a nice evening.
Kerry
I don't know if someone has clearly stated this, but specifically, dart frogs cannot survive outside of vivarium conditions. Upon escaping their tank, they have 2 minutes at best before becoming a dried piece of junk on the floor. Since chytrid does not have a resting spore, once dried, that frog is no threat to the outside world.
Also, the organization known as TreeWalkers International, Home | Tree Walkers International, has taken measures to assess the incidence of chytrid fungus within captive-bred collections. Most dart frog hobbyists can now have information at their fingertips on preventing and treating chytrid within their collection and take measures to do so. Furthermore, Dr. Reid Harris is currently doing research on pedobacter to kill chytrid fungus, and has had some encouraging results as of late. We would like for him to be able to test out his cure on our frogs as well.


I hope you are also aware that in order to save certain species, some species have to be 'reclaimed' by legitimate caretakers from those involved in smuggling and illegal trade. In some instances, without this opportunity, disallowing the transfer of these animals to private hobbyists would deny them care anywhere and thus the animal would be lost forever.
In many cases animals are not merely smuggled, but taken with care and specific intent by private individuals for the purpose of establishing a captive-bred population. In fact, laboratories would not have these specimens without the efforts of private individuals, for it is not the laboratory that risks life and limb in a harsh environment to obtain the specimens. Thus, you should consider the implications of limiting the importation of new, wild-caught specimens and be more specific as to which you refer---you seem as though you are lumping all the organizations together. One implication of this restriction would be the veritable loss of many valuable species through habitat destruction and an inability to save said species through importation.

I implore you to encourage an addendum (if you have any say in the lobbying for your proposal) to allow trade within members of private conservation efforts and their respective organizations, such as Tree Walkers International. This will allow individuals who are responsibly caring for said animals to be excluded from a crowd of people 'playing with frogs' who may or may not reasonably take precautions against the spread of this dreadful disease.

Thank you for your time,
 

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I'm going to say this: if one has tried to work with the USDA to just get a permit for shipping certain species of feeder insects-- one will know how very difficult they are to work with. They take weeks to respond just to a simple email "what is legal to ship and what not."

Recently, I emailed them and they took two weeks and didn't even answer my question, instead forwarded me to SOMEONE ELSE. When I asked the USFWS a simple question, "are xenopus frogs legal to ship to TX?" I got the same b/s and nobody could answer it-- everyone forwarded me to different people and were really slow just to respond.

I am all for testing my frogs for chytrid and getting them cleared of any and all infection. However, I would be completely against any and all type of "permit" before you could ship frogs because the incompetent beauracracy that thrives off of my tax dollars fails to do its job, while killing business. I don't mean to sound like a jerk when I insert my political opinion, but its been one of the most frustrating ordeals I've been through.
 

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Recently, I emailed them and they took two weeks and didn't even answer my question, instead forwarded me to SOMEONE ELSE. When I asked the USFWS a simple question, "are xenopus frogs legal to ship to TX?" I got the same b/s and nobody could answer it-- everyone forwarded me to different people and were really slow just to respond.

Your question would get answered more quickly if it was addressed to the correct govermental body.. It is the state of Texas who determines whether or not it is legal to ship Xenopus into the state of Texas not USF&W. USF&W would only get involved if it was illegal and they were notified of a violation as it would then be a Lacy Act violation.
 

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Although CITES permits can take as long as half a year to get even if you call multiple times(a week) and have your house representative file a congressional inquiry! So even if you do get the right office it can take a hell of a long time. Now try and impose this new system and see how long it takes!!!!
 

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Bumping this thread - today is the last day for comments everyone. The deadline is 11:59 pm Eastern Time at this address:

Regulations.gov

Please make constructive comments. For example, do not make blanket statements such as "this would be bad". Instead, make specific points and please try to cite references (there are plenty of reasons and citations in the threads here and here on dendroboard. Additionally there is a thread going on Caudata.org here).

Please do make a comment. Aside from the fact that the regulations could all but eliminate our hobby, the groundswell of informed opinion is that the regulations will do little to regulate the real culprits in chytrid spread, and the number of strains and their widespread presence in the wild in the US are points of history - there is no getting that cat back in the bag.

Lastly, this is another attempt by a very small but "fashionable" lobby group (Defenders of Wildlife) to impose their viewpoint on the American public, curtailing your freedom for their agenda. Even if you support the idea of these regulations, the least you can do is check your facts prior to just signing off on it - the sad fact is that few of the pro-ban folks really have much of a clue about the situation, or are they are pushing their own agenda/reinforcing their own jobs (sadly, reading the comment by its director, this now describes Amphibian Ark, an organization for which I've been a long time donor and supporter).

PS: I have not posted my own comment yet but I will before the deadline tonight.
 

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Here is what I have sent to the USFWS comments system tonight (view it as a PDF).

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
 

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Well tonite I finally overcame some writers block and submitted my opinion and statement on the proposal. And I also must tell you I went through all the submissions as of wed nite and I must say I was Very disappointed by the amount of names that should have been on their. I really hope it is a case of everyone waiting till the last minute. I would really be upset if so many people from here were afraid to speak up, stand up and be counted, while we still have that right. I think we should all, who are truly passionate about their amphibians, be interested to see who amongst us stood up, either way yes or no on the issue, and who sat back and felt lets let others decide whats best for us, I keep animals to learn from, enjoy, promote interest in, as well as income, I have no illusions I am saving the world through keeping frogs, like the sheeple that run with the humaniacs, I take possible banning of my passion very seriously, and I think everyone here should as well, my .02 cents, Bill
 

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There are also comments that were mailed in via hard copy. Those will be posted later however those also have the option to be posted with the names hidden.

Ed
 
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