# Is There Any Reason to Continue Supporting Amphibian Ark?



## Web Wheeler (May 9, 2010)

The Association of Zoos and Aquariums (AZA) OPPOSED the recent Defenders of Wildlife petition to the U.S. Fish & Wildlife Service to list all amphibians as injurious animals under the Lacy Act, unless certified as Chytrid Fungus free.

The American Veterinary Medical Association (AVMA) OPPOSED the recent Defenders of Wildlife petition to the U.S. Fish & Wildlife Service to list all amphibians as injurious animals under the Lacy Act, unless certified as Chytrid Fungus free.

The Pet Industry Joint Advisory Council (PIJAC) OPPOSED the recent Defenders of Wildlife petition to the U.S. Fish & Wildlife Service to list all amphibians as injurious animals under the Lacy Act, unless certified as Chytrid Fungus free.

The United States Association of Reptile Keepers (USARK) OPPOSED the recent Defenders of Wildlife petition to the U.S. Fish & Wildlife Service to list all amphibians as injurious animals under the Lacy Act, unless certified as Chytrid Fungus free.

*All of the above organizations have said that such a proposal would have very negative consequences for our hobby.*

I would suspect that most of the members here on Dendroboard are OPPOSED to the recent Defenders of Wildlife petition to the U.S. Fish & Wildlife Service to list all amphibians as injurious animals under the Lacy Act, unless certified as Chytrid Fungus free.

*So, I wonder, "Is There Any Reason to Continue Supporting Amphibian Ark?" who ADVOCATED FOR the recent Defenders of Wildlife petition to the U.S. Fish & Wildlife Service to list all amphibians as injurious animals under the Lacy Act, unless certified as Chytrid Fungus free.*


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## johnc (Oct 9, 2009)

We've been debating this over on Caudata.org for the past few days actually. We have, for the past few years, funded a research grant for amphibian conservation, overseen by AArk. Kevin Zippel/AArk's open support for the Defeners of Wildlife petition represents a direct conflict of interest with amphibian hobbyists. For the time being we've removed all advertising for Amphibian Ark (we had banners running constantly for them). I suspect we'll be running our own research grant directly in 2011.

To answer your question, it's a tricky answer. AArk have many positive attributes from the amphibian hobby's point of view, but how can we, as hobbyists, continue to support them if they are in favor of all but eliminating our hobby? I am sad to say that I can not in good conscience support them any longer. At least my personal donation to them earlier this year is tax deductible...


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## rcteem (Mar 24, 2009)

I understand that conservation in the wild is way more important than keeping our hobby and fully want to see conservation in the wild continue and grow...look at how for the past 5 years Ive been trying to do something in Brazil working with several international university and different biologist...but I still feel that the hobby is an important key to conservation. For example, the Highland Lamasi, aka Standards, are all most extinct and the ones in our hobby could vary well be that the last ones left in the world here soon. Now I know thats going out on a limb but these frogs alone are almost extinct but check the facts as even biologist have a tough time finding them and usually don't. Second look at all the deforestation going on. I have seen this first hand and can honestly say that is 10x worse than it was 5 years ago in several different regions. 

So at the rate AArk is growing and the rate we are losing the frogs to cythrid/ deforestation there wont be a hobby in 100 years because the frogs wont exist on the wild nor the hobby because the gov't is slowly pulling our rights away. I know Im might be causing some negative feedback by this post but these are my thoughts/ views and more than willing to have a civil argument on here with those that disagree so we both can learn facts we may not know


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## johnc (Oct 9, 2009)

Chris, I think the point is that AArk should have posted a more qualified comment than they did. Instead they took a black and white position. They should have taken into account the fact that they are partly funded by hobbyists. Sadly they did not. And there are now consequences for AArk, however slight.


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## Dendro Dave (Aug 2, 2005)

johnc said:


> Chris, I think the point is that AArk should have posted a more qualified comment than they did. Instead they took a black and white position. They should have taken into account the fact that they are partly funded by hobbyists. Sadly they did not. And there are now consequences for AArk, however slight.


Agreed....and with so many possible vectors for contamination beyond those caused by our hobby, and the fact that the proposed measures would have had minimal impact, it is just stupid for them to alienate a large portion of their supporters thus limiting how effective they can be in their goals. Dumb, dumb, dumb. kudos to them for the other good work they do, but this was a major screw up. I'm not inclined to support an organization that would sacrifice our hobby for so little, something likely to be barely effective if at all, or one who is prone to such screw ups.


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## JJuchems (Feb 16, 2004)

Organizations like this need funding in order to survive. Without the donations of hobbyist they would not exist, so why not hit them where it hurts the most. I would pull the plug on funding them. There is no greater way of letting them know they sold us out.


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## Ed (Sep 19, 2004)

JJuchems said:


> Organizations like this need funding in order to survive. Without the donations of hobbyist they would not exist, so why not hit them where it hurts the most. I would pull the plug on funding them. There is no greater way of letting them know they sold us out.


I am not defending thier choice... I am simply looking for the thoughts behind it. I'll probably have to look at thier mission statement and charter to see what it means. 

Ed


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## markpulawski (Nov 19, 2004)

So them saying they want all frogs being shipped certified Chytrid free to stop the possibility of further contamination (if it is even possible) is interpreted by everyone as they want to put an end to the amphibian hobby? Is that it or am I missing something?


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## Ed (Sep 19, 2004)

markpulawski said:


> So them saying they want all frogs being shipped certified Chytrid free to stop the possibility of further contamination (if it is even possible) is interpreted by everyone as they want to put an end to the amphibian hobby? Is that it or am I missing something?


That is the interpretation I've seen here. 

Has anyone let Kevin Zipple know? I think he has/had an account on here. 

Ed


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## JJuchems (Feb 16, 2004)

Mark, 
There are too many unanswered questions. 

What is "Chytrid Free"? (How many negative test needed, What about false positives?, Can you pool test?)
Who is going to regulate (USFWS or State Wildlife authority)?
Who is going to license/certify chytrid free (USFWS, USDA, State authorities)?
Are more labs going to be given the primers for the PCR test? (backlog)
Are the cost of testing going to be decreased? (doubt it)
How is the federal/state government going to afford to regulate this? (Another unfunded mandate)

Just a few off the top of my head. 

Cytrid is considered already widespread and WC animals should be treated as they if they are carriers. Why one more hurdle in when the spread of Bd may not just be in amphibians (migratory birds and fish).


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## JJuchems (Feb 16, 2004)

markpulawski said:


> So them saying they want all frogs being shipped certified Chytrid free to stop the possibility of further contamination (if it is even possible) is interpreted by everyone as they want to put an end to the amphibian hobby? Is that it or am I missing something?


I have a stance on the subject, similar to many of those on the board. If you do not agree with how an organization stood on an issue you feel strongly about, let them know about it. Individual support is what keeps these organizations going.


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## markpulawski (Nov 19, 2004)

I have a real problem taking a stance against A Ark, the amazing work they do world wide to offset a variety of pressures gives them legitmecy that few agencies have. Until I hear further I will not condemn their stance. There is always a bigger picture and i believe it has yet to be revealed to us, until then they have my support 100%. I would love to have Kevin come here and explain their stance, I will send an e-mail to a friend in the organization, hopefully they will respond.


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## frogface (Feb 20, 2010)

markpulawski said:


> I have a real problem taking a stance against A Ark, the amazing work they do world wide to offset a variety of pressures gives them legitmecy that few agencies have. Until I hear further I will not condemn their stance. There is always a bigger picture and i believe it has yet to be revealed to us, until then they have my support 100%. I would love to have Kevin come here and explain their stance, I will send an e-mail to a friend in the organization, hopefully they will respond.


<thanks button>


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## johnc (Oct 9, 2009)

markpulawski said:


> So them saying they want all frogs being shipped certified Chytrid free to stop the possibility of further contamination (if it is even possible) is interpreted by everyone as they want to put an end to the amphibian hobby? Is that it or am I missing something?


Given how inaccessible testing is to the hobbyist, and given how unfeasible it would be for us to test every frog we ever ship, my conclusion is the logical one, sadly. No one is more unhappy about that conclusion than I.


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## johnc (Oct 9, 2009)

markpulawski said:


> I have a real problem taking a stance against A Ark, the amazing work they do world wide to offset a variety of pressures gives them legitmecy that few agencies have. Until I hear further I will not condemn their stance. There is always a bigger picture and i believe it has yet to be revealed to us, until then they have my support 100%. I would love to have Kevin come here and explain their stance, I will send an e-mail to a friend in the organization, hopefully they will respond.


Up until this point I was circulating Amphibian Ark banners on every page loaded on Caudata.org for years. Caudata.org funneled thousands of dollars through Amphibian Ark for conservation. Can any other hobbyist amphibian organization say the same? I don't think so. We are quite literally the biggest hobbyist organization backing them. I think that deserved some consideration in how the AArk response was composed. Read the AArk response to the proposed regulation - there's no leeway in there, no ambiguity - it's black and white.


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## markpulawski (Nov 19, 2004)

Trust me there is more to this than meets the eye, I believe Kevin may make an appearrance here to explain their stance...until we hear from them let's not pass judgement.


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## SmackoftheGods (Jan 28, 2009)

markpulawski said:


> So them saying they want all frogs being shipped certified Chytrid free to stop the possibility of further contamination (if it is even possible) is interpreted by everyone as they want to put an end to the amphibian hobby? Is that it or am I missing something?


I'm not informed enough to make any judgements. However, as has been mentioned, chytrid testing seems pretty costly. To get a chytrid test done on _every single frog_ if I were to move, the cost wouldn't be worth staying in the hobby (however, I'd still pay the cost... 'cause I'm like that). It would also increase both the cost of buying and selling frogs ('cause you'd now have to get each frog you buy and sell tested).... It wouldn't be a direct end to the hobby, but it would certainly push it in that direction (my understanding, nothing more).


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## Kevin Zippel (Aug 28, 2009)

Hi all, Kevin Zippel here, director of the Amphibian Ark. I feel like a bit of an eavesdropper since people here have been speaking very frankly about the AArk. But Ed and Mark are correct, I am member of Dendroboard (I started my career as a hardcore hobbyist) and I did read these comments just now. No hard feelings, my wife thinks I act ‘dumb’ sometimes too, LOL! Anywho…there seems to be much confusion about what just went down in the Federal Register and why the AArk said what we said. Please allow me to break it down.

Our critics are absolutely right; we took a position that is not 100% in support of the hobbyist agenda. If the hypothetical regulation does come to fruition (if), and some (not all) shipped animals require testing (there is no proposed trade ban), the cost of shipping amphibians across US and state borders will likely go up by some as yet unknown amount to cover ‘certification’, and this additional cost will probably be passed along to the consumer, which might affect gross sales. And I am OK with that, if (and only if, as we stated previously and publicly) it helps wild amphibians, because my job is to help sustain wild populations of amphibians, not to sustain the commercial trade. I can understand how that might upset people who make their living shipping frogs, just as anyone who feels their livelihood is being threatened would be upset. But no one gets into selling frogs because it is the most lucrative business in the world, you do it because you love frogs. And if you really love frogs, then you have to be willing to consider changing your ways if (IF) what you are doing risks more harm than good. If you are not willing to have that discussion, then perhaps it is time to rethink why you are doing what you are doing. With all due respect, I love you guys and sing your praises all around the world. I actually get a good chuckle that zoos can’t breed their own pumilio and have to buy them from you but cannot in turn sell to a ‘lowly’ hobbyist, LOL! I know where the real expertise is, and trust me when I tell you that I preach that to the world (I was telling the bat people earlier today). So, have a little faith in me, and please hear what I have to say.

Here are the facts about Bd, as we know them today, taken from our position statement back in May (http://www.amphibianark.org/pdf/US_amphibian_trade_proposal.pdf). Bd kills. Bd occurs in regional strains that are not equally distributed. Bd is spread by trade. Trade is huge and Bd is not currently regulated in the trade. These are facts, not opinions. I would be happy to discuss them with anyone, share key publications, get you in touch with primary researchers, etc.

And here are the facts about what the USFWS is up to. They simply asked the world to provide them answers to 14 questions to help them decide whether trying to regulate Bd in the trade (all trade, not just pets) was needed, feasible and likely to be effective. No one said anything about a ban, mandatory testing, frequencies, costs, etc. So we at the AArk did our best to answer those 14 questions honestly and objectively. The only place we injected opinion is in our answer to Q14 where we said that we were in favor of regulating disease in the trade BUT “What remains to be seen is a proposal for effective implementation of such regulation” and “regardless of what form is proposed for this regulation, it is our hope and request that public feedback would again be sought and considered, as now, but that ultimate decisions are based on wildlife conservation and not business or personal considerations.” Read for yourself, here is our post in the Fed Reg Regulations.gov. We are not trying to bring down the trade, we just want to make it safer, where possible.

Regarding transparency: when the USFWS first announced back in May its intention to post something about Bd regulation in the Fed Reg, we posted our draft position on our website (http://www.amphibianark.org/pdf/US_amphibian_trade_proposal.pdf) as well as our blog and FB site. That was 7 months before the deadline. Our aim was to get out the facts, minimize unwarranted panic, and open up a dialogue among concerned partners. We invited feedback from anyone and everyone. In addition to scores of others, we discussed it with the folks from TWI who represent the US private sector on the AArk Steering Committee (we have 3 private sector reps on our SC, over 10%). Then in September, we saw that the posting in the Fed Reg would actually consist of 14 questions, so we modified our original position statement to fit into the 14 answers. Again we put the document out for feedback and got almost none (including from our friends at Caudata.org). That was 3 months before the deadline. We have been nothing but transparent about our interpretation, intentions, and request to discuss and consider alternate points of view. Did AZA do that with you? AVMA, PIJAC, USARK, etc.? Did anyone ask them why they are prioritizing the trade over the well-being of the species, or threaten to boycott them for putting capitalism before conservation? Ever hear those groups talking about how much the conservation community has to learn from the hobbyists, like I preach? Ever see them posting on Dendroboard at 3am because they were concerned about your opinions? ;-)

Long story short, my sole motivation in this job is to do what is best for wild amphibians. The day that changes is the day I go back to plumbing. If anyone has questions about any of this, I personally invite you to email me [email protected].

Finally, I am very sad to read here that Caudata.org intends to cut ties with us, and I will be speaking with John about that tomorrow. For the record, when they offered to raise some funds for us a couple years ago, I helped them to start their own grant program to funnel every single donated dollar into supporting conservation in the field (a project of their choosing) with nothing for us. All I wanted to do was give the hobbyists something to be proud of, to hold up and say that they are unselfishly supporting conservation in the wild. We still feature Caudata.org on our website and will continue to do so as long as they maintain the conservation grant. I would love to see the folks here on Dendroboard pull off something similar. In fact, I volunteer here and now my personal time to help you set up a conservation grant, just as I did with John, and I would love to see you fund that grant directly with the donations that you are no longer sending to us because you don’t like our policies. I am not being sarcastic, I am dead serious. That makes you feel happy about where your money is going, and it makes me pretty damn happy too. What say you?

Cheers,
Kevin


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## rcteem (Mar 24, 2009)

Thanks for posting and clearing up some things. It makes it clearer now for me, as I was one who owe you an apology. Sorry!!!


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## johnc (Oct 9, 2009)

Thanks Kevin. I see nothing new here though and I would challenge some of what you've just posted with peer reviewed references. However, I will refrain from further public comment on the matter of AArk's position.


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## rcteem (Mar 24, 2009)

SmackoftheGods said:


> I'm not informed enough to make any judgements. However, as has been mentioned, chytrid testing seems pretty costly. To get a chytrid test done on _every single frog_ if I were to move, the cost wouldn't be worth staying in the hobby (however, I'd still pay the cost... 'cause I'm like that). It would also increase both the cost of buying and selling frogs ('cause you'd now have to get each frog you buy and sell tested).... It wouldn't be a direct end to the hobby, but it would certainly push it in that direction (my understanding, nothing more).


I agree but I think that maybe then we will be conserving the frogs even more as we will know their health issues more and the frogs arent as cheap to buy and makes people want to research/care for their frogs more. Maybe will will see less of this bs that is going on here with mixed tanks and people wanting to hybridize their frogs if we are lucky enough


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## rhebert (Dec 3, 2009)

Kevin Zippel said:


> snip...
> Here are the facts about Bd, as we know them today, taken from our position statement back in May (http://www.amphibianark.org/pdf/US_amphibian_trade_proposal.pdf). Bd kills. Bd occurs in regional strains that are not equally distributed. Bd is spread by trade. Trade is huge and Bd is not currently regulated in the trade. These are facts, not opinions. I would be happy to discuss them with anyone, share key publications, get you in touch with primary researchers, etc.
> ...snip...
> 
> ...


Very cool! Information is key. Could you spare the slower of us the google time and post some links to the key publications that explain the scientific grounds for your position? Thanks!


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## Ed (Sep 19, 2004)

rcteem said:


> I agree but I think that maybe then we will be conserving the frogs even more as we will know their health issues more and the frogs arent as cheap to buy and makes people want to research/care for their frogs more. Maybe will will see less of this bs that is going on here with mixed tanks and people wanting to hybridize their frogs if we are lucky enough


 
One of the biggest things the hobby can do to help thier local frog populatiosns is to run all of the waste frog water to a storage tank and treat it with bleach before dumping it down the drain and not discarding any material from thier frog cages outside into the yard or compost heap. Instead they should be double bagged and discarded into the waste stream. 

Ed


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## Web Wheeler (May 9, 2010)

Ed said:


> One of the biggest things the hobby can do to help thier local frog populatiosns is to run all of the waste frog water to a storage tank and treat it with bleach before dumping it down the drain and not discarding any material from thier frog cages outside into the yard or compost heap. Instead they should be double bagged and discarded into the waste stream.
> 
> Ed


Simply bringing the waste water to a boil before discarding it would be a much better method of disinfection because no harmful chemicals are involved and disinfection is 100%. Similarly, heating solid matter in the oven to 200 degrees F for 30 minutes would bring about 100% disinfection in solids.


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## Ed (Sep 19, 2004)

Web Wheeler said:


> Simply bringing the waste water to a boil before discarding it would be a much better method of disinfection because no harmful chemicals are involved and disinfection is 100%. Similarly, heating solid matter in the oven to 200 degrees F for 30 minutes would bring about 100% disinfection in solids.


Actually, any excess chlorine can be easily neutralized by any aquarium dechlorinator. 

Boiling is not something that I personally would consider practical as it introduces the problem of infection of human food space with salmonella as amphibians are recognized carriers. It also wouldn't be practical based on volumes of water required. For example, when I had a larger aquatic collection in the past, I would easily generate ten to twenty gallons of waste water a day. A series of buckets allowed me to disinfect and neutralize the water. You can even purchase dechlorinators inexpensively through outlets like Aquatic Ecosystems. 

With respect to the solids, it has to be remembered that 30 minutes in an oven does not mean that the all of the debris has reached sufficient temperature for disinfection. You have to heat the material until all potential cracks and crevices have reached the appropriate temperature, which is often undetectable. 
This is also ignoring the potential risk of salmonella as well (and goes against the health recommendations of ARAV and if I remember correctly NIH). 

Ed


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## Azurel (Aug 5, 2010)

I can appreciate AArk's position and won't question it as I don't know enough about them, but the ones I question are the ones that are pushing the agenda, Defenders of Wildlife and Center for Biodiversity. They are the major players in most of these regulations and petitions. I know for fact when considering the reefing hobby and trade an all out ban is the be all end all of there positions irregardless of CB or WC. So why would it not be the same here with amphibians? We can agree a trade with BD is not good for the hobby or wildlife. But the answer comes down to money, cost of implementation and regulation. In the end it will be to expensive for the Government to implement and regulate, so then they will petition for an all out ban which will cost either party nothing and you and I our hobby. 

The problem with these things is the creeping incrementalism, they take them away little by little and before your know it we are left with nothing.....One of the things I would require is a detailed plan of the regulation with every facet described in detail. This way we have the information as to the over all impact and detailed impact of the petitions and regulations before I could think of supporting it. But in these matters they keep them ambiguous which allows them to be able to deny exactly what people here are afraid of. Then after the chance for us to stop it, the details get worked out and we find ourselves with something that is entirely different then what we supported in the beginning. Let's not forget this is the same government and agencies that pass law with out reading what is in it. The same government and agencies that are trying to circumvent the legislative body that is supposed to deal with making and creating law along with the will of the people no matter if it is a majority or minority....Are these the folks that you really want to trust with ambiguous petitions and regulations?.....Not to mention those that are supporting these petitions( other then AARK) who's whole plan is total ban of captive housing and care of wild animals under the guise of "conservation".

I think everyone can agree BD is dangerous, should have some regulation within certain sectors that deal with amphibians. I am willing to pay more for frogs due to regulations that keep them and the wildlife safe, but it sure as hell better due what I am being forced to pay higher cost for.
But in this case I say no thanks due to those that have called for the petition and the ambiguity of the the petition and details, cause I for one don't trust any of them.


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## Ed (Sep 19, 2004)

Azurel said:


> .
> 
> One of the things I would require is a detailed plan of the regulation with every facet described in detail. This way we have the information as to the over all impact and detailed impact of the petitions and regulations before I could think of supporting it. But in these matters they keep them ambiguous which allows them to be able to deny exactly what people here are afraid of. .


The following is based on the theory that a regulation could be put in place.. it is not a position of support for the regulation of trade in amphibians..... 

*If on review, * *USF&W determines *that the amphibian trade with respect to Bd, then that would have to be regulated for Bd transmission, then a proposed set of regulations would have to made which if I understand the process correctly, should also be open for further comment by the hobby and industry.... 

If I understand the procedure, it would also be open to pressure from the legislature which means lobbying representatives..


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## Azurel (Aug 5, 2010)

Ed said:


> The following is based on the theory that a regulation could be put in place.. it is not a position of support for the regulation of trade in amphibians.....
> 
> *If on review, * *USF&W determines *that the amphibian trade with respect to Bd, then that would have to be regulated for Bd transmission, then a proposed set of regulations would have to made which if I understand the process correctly, should also be open for further comment by the hobby and industry....
> 
> If I understand the procedure, it would also be open to pressure from the legislature which means lobbying representatives..


Thanks for the clearification Ed.......Atleast I would hope we would still have a say in the matter.....


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## Kevin Zippel (Aug 28, 2009)

rhebert said:


> Very cool! Information is key. Could you spare the slower of us the google time and post some links to the key publications that explain the scientific grounds for your position? Thanks!


per rhebert’s request:

• Infections with Batrachochytrium dendrobatidis (Bd) can be deadly for amphibians; Bd has already affected over 350 species and caused the decline or extinction of about 200 of them. 
http://www.erin.utoronto.ca/~w3bio/bio335/lectures/lectures_assets/reading_global_emergence.pdf 
http://www.jcu.edu.au/school/phtm/PHTM/frogs/papers/skerratt-2007.pdf. 

• Although Bd is already widespread, it occurs in regional strains that can affect amphibians differently, i.e., the potential remains for this disease to do much more harm with further spread.
http://www.int-res.com/articles/dao2005/68/d068p047.pdf
Proteomic and phenotypic profiling of the amphibian pathogen Batrachochytrium dendrobatidis shows that genotype is linked to virulence - FISHER - 2009 - Molecular Ecology - Wiley Online Library
Strain differences in the amphibian chytrid Batrac... [Dis Aquat Organ. 2007] - PubMed result
There are others, which I can provide if necessary

• Trade plays an unequivocally significant role in spreading Bd.
http://www.jcu.edu.au/school/phtm/PHTM/frogs/papers/fisher-2007.pdf
Amphibian chytridiomycosis in Japan: distribution, haplotypes and possible route of entry into Japan - GOKA - 2009 - Molecular Ecology - Wiley Online Library
Amphibian commerce as a likely source of pathogen ... [Conserv Biol. 2008] - PubMed result 
http://bio.research.ucsc.edu/people/kilpatrick/publications/Schloegel et al 2009 Biol Cons.pdf 
http://www.jcu.edu.au/school/phtm/PHTM/frogs/papers/garner-2006.pdf 
http://bd-freephibs.com/fungpp7.pdf 
http://www.cdc.gov/ncidod/EID/vol10no12/pdfs/03-0804.pdf 
And many others

• While amphibian trade into, out of, and within the US is considerable, there are currently no regulations to minimize the risk of spreading disease.
Amphibian commerce as a likely source of pathogen ... [Conserv Biol. 2008] - PubMed result 
http://bio.research.ucsc.edu/people/kilpatrick/publications/Schloegel et al 2009 Biol Cons.pdf 
http://www.jcu.edu.au/school/phtm/PHTM/frogs/papers/garner-2006.pdf 
And many others

Again, I am happy to discuss any of this with any of you, provide more papers, full papers where only abstracts are available online, introduce you to researchers, whatever it takes to get the facts on the table.

cheers, kcz


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## Kevin Zippel (Aug 28, 2009)

Thanks Ed, for your comments on waste treatment. You are right, all solid waste should be bagged and sent to the landfill, as awful as it might sound to do that with something that is otherwise compostable. Liquid wastes should, at the very least, be run down the drain to a septic tank or municipal treatment plant. However, we know that some pathogens can survive that trip (e.g., domestic cats infecting sea otters) so if it is possible and practical, treat it yourself then run it down the drain, never outside. For good bedtime/bathroom reading, check out http://www.cbsg.org/cbsg/workshopreports/26/amphibian_disease_manual.pdf. this is not a bad read either How Can I Help? « Amphibian Ark.


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## Vermfly (Jun 6, 2010)

Kevin, looking through the links you provided it seems that the bait and food trade in amphibians seem to be the largest vectors followed by the pet trade in a few species like dwarf clawed frog, American bullfrog and cane toad. Why not make sure that is included in your comment to the US F&WS? It would seem that limiting the trade in those species and amphibians used for the food and bait trade would greatly limit the spread of Bd.


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## markpulawski (Nov 19, 2004)

A quick comment from the ever elusive Ron Gagliardo..

"I sometimes oversimplify things in my tiny brain but for me, the underlying question is "would it be a good thing to limit the spread of a disease that is KNOWN to be associated with amphibian extinction and thus simply open up a discussion on how we could work together to do this? " Of course it would and this is all it is now for the foreseeable future. Note, there is nothing mentioned in this question about shutting down the pet trade. 


The second question in my mind is: "Can USFWS or any other organization come up with an effective plan to regulate the spread of disease in the trade of any amphibians (pets, food, bait, etc.)?" I would not hold my breath." 

Sage words from one of the Pacific North West's newest residents
...Atlanta's loss is Seattle's gain, my trips up I-75 have a lot less meaning now.


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## Ed (Sep 19, 2004)

Kevin Zippel said:


> Thanks Ed, for your comments on waste treatment. You are right, all solid waste should be bagged and sent to the landfill, as awful as it might sound to do that with something that is otherwise compostable. Liquid wastes should, at the very least, be run down the drain to a septic tank or municipal treatment plant. However, we know that some pathogens can survive that trip (e.g., domestic cats infecting sea otters) so if it is possible and practical, treat it yourself then run it down the drain, never outside. For good bedtime/bathroom reading, check out http://www.cbsg.org/cbsg/workshopreports/26/amphibian_disease_manual.pdf. this is not a bad read either How Can I Help? « Amphibian Ark.


Hi Kevin,

I made/make the recommendation to treat waste water as not only can some pathogens survive the treatment plants but because in many older US cities and towns, the sewer system and the street runoff all are part of the same network and a heavy rain can overload the system causing untreated waste water to be released into the waterways. This is a conservative recommendation based on the potential survivial and reducung risk of release 

Ed


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## Ed (Sep 19, 2004)

*OT Re: Is There Any Reason to Continue Supporting Amphibian Ark?*



markpulawski said:


> \
> Sage words from one of the Pacific North West's newest residents
> ...Atlanta's loss is Seattle's gain, my trips up I-75 have a lot less meaning now.


Mark, 
Did Ron move to the Northwest? 

Ed


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## SmackoftheGods (Jan 28, 2009)

Kevin Zippel said:


> And I am OK with that, if (and only if, as we stated previously and publicly) it helps wild amphibians, because my job is to help sustain wild populations of amphibians, not to sustain the commercial trade.


Forgive me, I'm just trying to get a handle on everything. The proposition in question was merely a discussion about the potential for imposing regulations, right? If AArk's posted position was simply "this possible actions has some potential and deserves to be discussed further" then I suppose I'm okay with that. If the proposition in question is _anything_ more severe than discussing the possibility that regulation may help reduce the spread of chytrid (sorry, apparently I haven't done my homework) then it seems like you have way too many "ifs" to support the rule.



Kevin Zippel said:


> Here are the facts about Bd, as we know them today, taken from our position statement back in May (http://www.amphibianark.org/pdf/US_amphibian_trade_proposal.pdf). Bd kills. Bd occurs in regional strains that are not equally distributed. Bd is spread by trade. Trade is huge and Bd is not currently regulated in the trade. These are facts, not opinions. I would be happy to discuss them with anyone, share key publications, get you in touch with primary researchers, etc.


I apologize to him, but there's someone a lot more educated on the situation that I am who posted these facts in another thread. What do you think about this:



Ed said:


> 1) The USDA has ruled that chytrid is unactionable...
> 2) It is widespread and endemic in the country
> 3) implementation would do widespread harm..



Personally, if Bd tests were more readily available and at an affordable price, I'd probably get my frogs tested _anyway_. I sent in some swabs to TWI when they requested we send some in to see how intense Bd was in hobby frogs. But right now, I don't even know where I could _go_ to send in a Bd test. It's not like parasites that just about any vet could at least take a stab at diagnosing....

Also, Chris, I'm actually right there with you. If forced Bd testing were implemented, which increased prices, which inspired more education, which decreased people's desire (and desire to post about) to mix, then I'm _all_ for it! Sadly, that's a really big "if."


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## JJuchems (Feb 16, 2004)

Out of the 4 labs listed on AArk website, only 3 will PCR test for the consumer. And I have been quoted between $10-30 a test and average return time of 10-14 weeks. Three labs are not enough. 
List can be found here: Chytrid Fungus « Amphibian Ark

The institution that will not: San Diego Zoo Institute for Conservation Research due to "restrictions to our grant funding and institutional mission." 

Do I feel jaded by AArk, yes. There response is reflected of you major donors and one of the organizer (AZA). Zoo have no problem looking to the hobby to acquire stock and methods of reproduction. Anything else, they could care less for us. 

AARk Donor List: Our Donors « Amphibian Ark

Public Comments: Regulations.gov

I have no problem with testing my collection, but what are going to be the parameters and protocols set by USFWS? Who is going to regulate this? Who going to pay for it? I live in state that has a hug debt problem as it is and I am going to assume we will all end up paying for permit system. Let alone some sort of enforcement.


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## markpulawski (Nov 19, 2004)

*Re: OT Re: Is There Any Reason to Continue Supporting Amphibian Ark?*



Ed said:


> Mark,
> Did Ron move to the Northwest?
> 
> Ed


Yes he moved to Seattle a few weeks ago.


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## johnc (Oct 9, 2009)

I know I said I wouldn't comment further but I've changed my mind. 

Kevin's agenda is definitely pro this blanket regulation (and in the proposed form, that will end our hobby to all intents and purposes) and he has posted references that are distinctly supporting that agenda. "Facts", eh? A lot isn't known about chytrid, including definitively where it's from, and there's a lot of contradictory information. If you want some more "Facts" from an informed opinion on "our side" of the topic, read my comment - there are plenty of top flight references given to back it up.

Frankly, I am alarmed at how readily many of the folks in this thread have somehow been assuaged by Kevin's initial post. Yes Amphibian Ark seeks to conserve amphibian species and we are all in favor of that aspect of their mission. What I, and I believe Web Wheeler and Vermfly are trying to point out is, despite our support of AArk's core mission, their comment on the regulation is 100% unambiguously behind the Defenders of Wildlife proposal. The Defenders of Wildlife seek to ban all pets, perhaps save dogs and cats. 

Amphibian Ark is supporting that organization's blanket proposal without a thought for us. Did you see a comment like this from Amphibian Ark or Defenders of Wildlife?



> Amphibian hobbyists are more than likely not to blame for this and they will suffer the most unless we tweak the proposal slightly. By the way, look at that TWI study where only 2 from 273 samples had chytrid. Much of the work done by researchers, zoos, and conservationists is based on the discoveries and experience of amphibian hobbyists - perhaps we should spare a thought for them?


In case we forget, Kevin and his organization have a vested self-interest in backing this proposal as it stands. This is a big PR opportunity, and it helps both the organization and its employees blow their trumpets for the world and funding bodies to see. If standing up and giving unqualified backing to this proposal, as they have done, is in their interests, of course they're going to do it - their jobs rely on the PR they receive and their perceived effectiveness as an organization.

So to sum up, AArk's comment does represent a distinct conflict of interest with our hobby. Kevin can dress it up and put make-up on it, it's still directly against our hobby. To everyone jumping on board with Kevin's fluffy comments, ask yourself where Kevin/AArk were when they were formulating their comment. Did they once come on here and ask your opinion? How many of you even knew he had an account here? He certainly never said one word to us over at Caudata.org. Amphibian hobbyists didn't figure in his composition (and that might well be fine, considering his organization's mandate), but a token consultation, or a word of warning would sure have been nice. 

Getting back to the Caudata.org grant issue, we threw money at Amphibian Ark for the last 2 years for these grants. We are not a commercial organization, nor does Caudata.org go on any of our CVs/resumes, so we get nothing out of it personally or professionally. None of us are employed in what we do, unlike Kevin at AArk. Our sole motivation was to help amphibian conservation. We all, quite rightly I believe, feel used and ignored by Amphibian Ark as a result. With one hand Amphibian Ark took our money to help conservation but with the other hand AArk was endorsing the end of our hobby.

We all agree Chytrid/Bd is a terrible thing and if we can somehow fight it then we should. However, the time for a ban like this was at least 8 years ago, and the "facts" are that we are not even sure if a strain of this disease was not endemic in the Eastern US long before humans discovered it (see my comment for the references) and may even have evolved here.

Having read many of the responses on regulations.gov, and comparing them to Amphibian Ark's, it is clear that by endorsing AArk you are running the risk of destroying your own hobby. That is a fact. Read Defenders of Wildlife's proposal and then read AArk's comment if you want to verify that fact.


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## SmackoftheGods (Jan 28, 2009)

I'm sorry, I had another question (and some foundation to lay before I actually _ask_ the question):



Kevin Zippel said:


> Bd kills. Bd occurs in regional strains that are not equally distributed. Bd is spread by trade. Trade is huge and Bd is not currently regulated in the trade.


Bd kills, I'll grant this. Bd _occurs_ in trade/hobby, I'll grant this (considering I just read the TWI chytrid thread again and saw that two tests came back positive, it _does_ occur in trade). Trade is huge and Bd is not currently regulated in the trade, I'll grant this.

What I'm not seeing from these facts is how these facts show that the spread of Bd to wild amphibian populations is affected (at least in a significant way) by the pet trade.

Here's something that was posted by someone who, again, I think knows more than me about this subject:



rcteem said:


> Does the pet trade really contribute to the spread of chytrid, at this point in time? Most amphibian experts will tell you that the majority of the disease's spread is due to the bait fishing industry and the amphibians as food industry. Bait fishermen use tiger salamander tadpoles to fish for bass. These tadpoles are often infected with chytrid from other parts of the country and when they are used as bait they introduce chytrid to that water source. The fisherman also have a bad habit of letting their bait go at the end of the day. The frog legs/amphibian as food industry is largely responsible for the spread of the American Bullfrog, which is very tolerant of chytrid, making it a great carrier of the disease. Waste water from these frog rearing facilities can carry chytrid.


Assuming the above quote is correct, wouldn't it make more sense to go after the culprits mentioned above to at least _see_ if Bd regulation could be realistically and effectively implemented?

What facts are there (and I don't mean this to be a rhetorical question, I _really_ want to know) that the pet trade is responsible for significant numbers of amphibians being affected by Bd? Especially considering that the TWI tests came back with only a .7% positive Bd result (which, granted, is not necessarily representative of the pet trade as a whole, but then again, I made sure to swab one of my wild caught frogs very thoroughly because I figured if there was a Bd threat in my collection it would come from them.... I did not have one of the two tests that came back positive).

I don't know, it just seems like these regulations are coming too little too late, and they _seem_ to be directed at a group of people who do less harm and care more about the harm that they do than most other groups who hold equal (probably greater) accountability (let's face it, how many people on this board do you think would be okay with sacrificing tadpoles so they could catch a fish?)


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## rhebert (Dec 3, 2009)

Kevin Zippel said:


> per rhebert’s request:
> 
> • Infections with Batrachochytrium dendrobatidis (Bd) can be deadly for amphibians; Bd has already affected over 350 species and caused the decline or extinction of about 200 of them.
> http://www.erin.utoronto.ca/~w3bio/bio335/lectures/lectures_assets/reading_global_emergence.pdf
> ...


Thanks for the reading material. I kind of get the impression, though, that the proposed law would be closing the barn door after the horse is out. Also, it is a little discomforting that the fear of bd also plays into the agenda of FoA. Of course there is no way to know for sure what their motivation is, but it makes one wonder.

Here is a link to a study of North American leopard frogs. 
Prevalence of the pathogenic chytrid fungus, Batrachochytrium dendrobatidis, in an endangered population of northern leopard frogs, Rana pipiens


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## Vermfly (Jun 6, 2010)

Kevin, I would love an answer to my question. Since it appears the food and bait trade in amphibians seem to be the main vectors in your cited literature followed by the pet trade in just a few species such as African clawed frogs, cane toads, and American bullfrogs why wouldn't your statement present the more reasonable view that trade in those species and for those purposes be the ones focused on by the US F&WS?


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## Kevin Zippel (Aug 28, 2009)

OK frog fans, I have no interest in a public flame war, I just came here to state the facts for what they are. I will post a few more facts, for the record, and then I will bow out and let you all get back to your frogging.

1. Jake’s first thought is correct; the proposition in question is merely a discussion about the potential of regulation, not about a ban or an ‘attempt to end your hobby’. If anyone has any doubt about that, please read the background and 14 questions directly from the USFWS for yourself (Regulations.gov) - no mention of bans , right? I will make dinner for anyone who finds one. The only reason the USFWS is doing this now is because DOW filed a petition for them to take some action, and all they are doing is asking 14 questions. What is DOW’s motivation? They are simply asking the USFWS to adhere to the advice of the OIE, of which the US is a signatory member… in other words, to do their job. I have never seen in writing, and challenge someone to show me, that “The Defenders of Wildlife seek to ban all pets, perhaps save dogs and cats.” There’s another dinner if you find it. I am absolutely dumbfounded by the truth twisting at play here. I am not interested in anything but the facts and I have no interest in arguing with people who ignore or twist them.
2. Nobody is singling out the hobbyists; regulations (should they ever come to pass) would cover all forms of trade, including food, bait, pets, research, and zoos. 
3. Jason is correct, there are not currently enough labs to do Bd testing on a large scale, and if the USFWS intends to mandate testing (IF), then they obviously have to make it more available or be subject to your lobbying power. But if you read the 14 questions, you will see that they are clearly not ready yet to discuss details of implementation, they are just gathering info regarding need and feasibility.
4. While we might not know exactly where Bd came from, that is irrelevant because we do know (1) that there are places where it was not native and devastated wild amphibian populations (Australia, Europe, South America, Central America, the Caribbean, western US) when it was introduced by people and (2) that different strains have different virulence and are not yet found all around the world. 
5. The AArk has had absolutely no PR related to the proposed regulation (another dinner if you find any), and our funding is in no way linked to PR. The majority of our funding comes from the zoo community, who pays us even when we do not agree, so we have no obligation to tow any company line. We say what we think is right even when it does not agree with our primary funding source. I have nothing to gain by this regulation, other than better protection of wild frogs.
6. Again, I did send JohnC a draft of our Fed Reg response 3 months ago and specifically asked for his feedback; I have the email record to prove it. However, he chose not to reply. He had every opportunity to weigh in so I cannot understand his current surprise and hostility and attempts to publicly broadside me. The entire world has had 7 months to read our draft reply online and reply. Name one other org that did this, other than DOW, and there’s another free dinner.
7. AArk did not keep a single dollar from Caudata.org, every penny was forwarded to the grant winners and we have the records to prove it. We even paid for the wire transfer and staff time to manage the grant. We used no one, we only tried to help hobbyists connect to field conservationists, which was and is a good thing to do.

The only outstanding issue is, if USFWS does decide that regulation of Bd in the trade is worth pursuing (if), how will they define ‘certified free of Bd.’ And as Ed so rightly pointed out, that too will be an opportunity to voice your concerns and exert your lobbying power. Stage 1 was just asking you if it was worth pursuing the idea of regulating disease in the trade, not what that regulation would look like.

You may do with these facts as you will. If anyone wants to discuss the facts and the AArk’s actions, please email me off list because I don’t want to play games and am signing off DB. My offer to help DB divert your money from the AArk to your own conservation grant program still stands.

Peace all, happy solstice, and you are welcome to come over for dinner anyway, even when you can’t find the missing mis-info requested above!
kcz


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## Vermfly (Jun 6, 2010)

I feel like I'm asking a perfectly reasonable question. Why are you refusing to answer?


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## SmackoftheGods (Jan 28, 2009)

Kevin Zippel said:


> 2. Nobody is singling out the hobbyists; regulations (should they ever come to pass) would cover all forms of trade, including food, bait, pets, research, and zoos.


I think that _was_ intended to be your answer, Vermfly....


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## Tony (Oct 13, 2008)

Vermfly said:


> I feel like I'm asking a perfectly reasonable question. Why are you refusing to answer?


The resemblance to Kerry Kriger is striking...


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## Vermfly (Jun 6, 2010)

Yeah, odd that I didn't recognize that as an answer. Since it avoids the real question I asked.


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## Vermfly (Jun 6, 2010)

Tony said:


> The resemblance to Kerry Kriger is striking...


Really... I'm not sure they aren't the same person anymore.


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## markpulawski (Nov 19, 2004)

There are at least 2 threads current here now about Chytrid and it killing parts or all of a collection and i have lost 2 complete collctions early on to this insidious fungus. Maybe it is too late to stop where it will eventually end up but damning AA and their efforts to support some controls regarding this does not to me equate them trying to end our hobby. Does this regulation also endorse the Defenders of Wildlife group mentioned here?
Seems like there are 2 different topics at hand.
I too would hate to have my animals tested and pay for something I feel pretty sure I know the answer to but I will not condemn AA for trying to protect amphibian populations that may yet be affected.


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## Vermfly (Jun 6, 2010)

I agree with the goal of protecting wild amphibian populations but my argument would be that our collections pose a very small risk which can be managed. 

The law should focus on those species known to be carriers of chytrid to a high degree. According to the literature Kevin cites bullfrogs raised for food can carry chytrid at a rate of 66%. The food and bait trade in amphibians are the main vectors of chytrid so the regulation should focus on that and I think Kevin statement to the US F&WS should reflect that, especially if he expects to keep receiving any support from this community. Secondarily the proposed rules could focus on the main vectors that are in the pet trade like African clawed frogs, American bullfrogs and cane toads, all of which are known to be resistant to chytrid and major carriers of the fungus.


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## SmackoftheGods (Jan 28, 2009)

Vermfly said:


> Yeah, odd that I didn't recognize that as an answer. Since it avoids the real question I asked.


Yeah....

But I think the _intention_ of what was said was that hobbyists aren't being singled out, and with the regulations on pet trade both the bait industry as well as frogs for food would be subject to the same regulations.... Just my interpretation.


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## Vermfly (Jun 6, 2010)

SmackoftheGods said:


> Yeah....
> 
> But I think the _intention_ of what was said was that hobbyists aren't being singled out, and with the regulations on pet trade both the bait industry as well as frogs for food would be subject to the same regulations.... Just my interpretation.


I do think that is what he intended with that statement. I actually am asking the opposite question, which is why not single out the groups that are the main vectors instead of limiting the pet trade in species that die of chytrid and so don't carry it at a high rate?


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## SmackoftheGods (Jan 28, 2009)

Vermfly said:


> I do think that is what he intended with that statement. I actually am asking the opposite question, which is why not single out the groups that are the main vectors instead of limiting the pet trade in species that die of chytrid and so don't carry it at a high rate?



huh... makes sense to me.... If they start having a discussion about how best to implement it and regulations and everything else, why don't you make that suggestion? I'd back you


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## markpulawski (Nov 19, 2004)

Vermfly said:


> I agree with the goal of protecting wild amphibian populations but my argument would be that our collections pose a very small risk which can be managed.
> 
> The law should focus on those species known to be carriers of chytrid to a high degree. According to the literature Kevin cites bullfrogs raised for food can carry chytrid at a rate of 66%. The food and bait trade in amphibians are the main vectors of chytrid so the regulation should focus on that and I think Kevin statement to the US F&WS should reflect that, especially if he expects to keep receiving any support from this community. Secondarily the proposed rules could focus on the main vectors that are in the pet trade like African clawed frogs, American bullfrogs and cane toads, all of which are known to be resistant to chytrid and major carriers of the fungus.


Agreed a small risk but take the 2 examples on the board now, 1 in California and 1 in Canada, suppose those deceased frogs in each case were carelessly disposed of without knowledge they were carrying Chytrid and suddenly other amphibians were exposed, through a dump or landfill to the infected frog flesh (sorry I just love using the word flesh today). These native populations could theoritically then spread it all over an area where it had previously not been known. Just playing devils advocate here but in my mind this is a pretty realisitic scenario based on the comments made in those threads...other than amphibians being in a landfill or dump, but the runoff water from such could carry the fungus. I just don't see AA being the bad guy here, sure they are trying to impose things that make my hobby less fun and more expensive (and thanks to Ford something I could not afford now) but in the end to me at least it is doing the right thing. I can't condemn them for adding to my burden but at the same time making me do what's best.


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## Vermfly (Jun 6, 2010)

Ultimately I believe the hobby would survive this kind of regulation. As for the dead frogs ending up in a landfill, I think bagging in plastic and disposing into the waste stream is actually the protocol for infected tank materials so I don't see that being a major risk.


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## markpulawski (Nov 19, 2004)

If everyone bags their dead frogs, that would be a good poll for someone to put up...what do you do with your deceased frogs??


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## Vermfly (Jun 6, 2010)

I believe that poll is currently running. Unfortunately that isn't given as an option. I'd actually favor a necropsy to determine cause of death and disposal by incineration like any medical waste.


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## kikker (Mar 4, 2007)

I can't add anything new to the information and clarification that Kevin wrote except perhaps to further point out the obvious, which Mark posted a couple of days ago (quoted from a private message I sent to him): 


"I sometimes oversimplify things in my tiny brain but for me, the underlying question is "would it be a good thing to limit the spread of a disease that is KNOWN to be associated with amphibian extinction and thus simply open up a discussion on how we could work together to do this? " Of course it would and this is all it is now for the foreseeable future. Note, there is nothing mentioned in this question about shutting down the pet trade. 


The second question in my mind is: "Can USFWS or any other organization come up with an effective plan to regulate the spread of disease in the trade of any amphibians (pets, food, bait, etc.)?" I would not hold my breath." 


The point being that at this point, this is ONLY a discussion and nothing more. Even if legislation comes down the pipe, we're talking years and as we know there are many more hurdles. So why not take a deep breath, relax and look at things we can do now? Anyone want to come show off their husbandry skills helping to teach at an AArk workshop? Anyone want to start a DB small grant program? Anyone up for helping fund a student in need get to a workshop? There's so much to do rather than trying to interpret what each is saying, etc. Amphibian Ark does not require a "recipient profile" form or credit check so if you have ideas, bring 'em. Dinner at Kevin's will be "farm to table," guaranteed!
And per Kevin's challenge, if DB decides to pursue funding conservation work through some type of grant program, let us know. I'll be your first contributor!

Happy Holidays!

Best,
Ron


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## Ed (Sep 19, 2004)

markpulawski said:


> Agreed a small risk but take the 2 examples on the board now, 1 in California and 1 in Canada, suppose those deceased frogs in each case were carelessly disposed of without knowledge they were carrying Chytrid and suddenly other amphibians were exposed, through a dump or landfill to the infected frog flesh (sorry I just love using the word flesh today). These native populations could theoritically then spread it all over an area where it had previously not been known. Just playing devils advocate here but in my mind this is a pretty realisitic scenario based on the comments made in those threads...other than amphibians being in a landfill or dump, but the runoff water from such could carry the fungus. I just don't see AA being the bad guy here, sure they are trying to impose things that make my hobby less fun and more expensive (and thanks to Ford something I could not afford now) but in the end to me at least it is doing the right thing. I can't condemn them for adding to my burden but at the same time making me do what's best.


 
Modern landfills/dumps have to control runoff from the dump/landill as well as preventing leachates from exiting the landfill. This is why landfills are sealed with various liners etc. 

If the deceased frog is double bagged and discarded into the waste stream that is about as safe as most people can get unless they know if any of the local vets/shelters have cremation facilities. In those cases, inclusion as part of a cremation is an even better solution. 

If you want to be really paranoid, you could always pickle the deceased frog in 100% etoh as this will kill the fungus before discarding the frog... 

Ed


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## johnc (Oct 9, 2009)

Kevin Zippel said:


> 5. The AArk has had absolutely no PR related to the proposed regulation (another dinner if you find any), and our funding is in no way linked to PR. The majority of our funding comes from the zoo community, who pays us even when we do not agree, so we have no obligation to tow any company line. We say what we think is right even when it does not agree with our primary funding source. I have nothing to gain by this regulation, other than better protection of wild frogs.


The PR value is that you are seen publicly trumpeting AArk's "position", thus reinforcing the perceived necessity of your organization and your own personal job.



Kevin Zippel said:


> 6. Again, I did send JohnC a draft of our Fed Reg response 3 months ago and specifically asked for his feedback; I have the email record to prove it. However, he chose not to reply. He had every opportunity to weigh in so I cannot understand his current surprise and hostility and attempts to publicly broadside me. The entire world has had 7 months to read our draft reply online and reply. Name one other org that did this, other than DOW, and there’s another free dinner.


Firstly, that was not a draft of your comment. it's a completely different document in structure, length, and composition. You had posted that document online, and the Caudata.org mods, admins and myself had all read it by the time you emailed it to me. At that point it was old news. 

The only part of the document you sent me that was relevant to your actual comment as submitted was the following:



Kevin Zippel said:


> We will comment in the Federal Register (and encourage our partners to do the same) that regulation to effectively reduce the role of amphibian trade in spreading disease can only be a good thing for captive and wild amphibians. We will then encourage development of some forum where experts and stakeholders can get together for productive discussion of whether, and exactly how, regulation might effectively diminish disease in the trade. But the first step is to let the government know that you think that reducing disease in the amphibian trade is a good thing!


As I said previously, in no way is there an indication of your exact position on the regulation. This just told me that you were for regulation, not that you were going to completely endorse the Defenders of Wildlife proposal as written. I did not respond because I do think regulation of chytrid may have its merits, but certainly not in the form the Defenders of Wildlife have proposed. I thought you, in your professional position and with your experiential background, would have tempered your response to take into account logic and reason (i.e. the horse is out of the barn by at least 8 years, there is no approved standard test for chytrid, perhaps regulation should be aimed at the main culprits, namely the bait and food industries). Our only fault at caudata.org was expecting you to give a scientifically rational response, and not a wholehearted endorsement. 

I will freely put my hands up and say sorry, having read that emailed document a few times way back when, I really had a high opinion of how you would actually respond - I did not expect you to give carte blanche to Defenders of Wildlife.


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## JJuchems (Feb 16, 2004)

This may also speak of AArk support of Defenders of Wildlife. 

Jeff Corwin Video on AArk
Videos « Amphibian Ark

Jeff Corwin, Executive Board member of Defenders of Wildlife
Board of Directors and Advisory Committees - Defenders of Wildlife


Don't get me wrong. I have known this for a while and he is a great voice for any group. I use his videos on Discovery education in my classroom and have meet him at a fundraiser for the zoo I once worked at. 

Board of a Group that spoke in favor of HR 669, when Jeff owns a pet fennec fox.


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## Rain_Frog (Apr 27, 2004)

I rarely comment on these type of threads (which are becoming VERY common now compared to when I first joined this forum), but here goes...

People are getting hysterical. What did I say? *People are getting hysterical.* 

Do you really think the government is going to spend even more money on just conserving frogs when the pet industry is growing, and taking in consideration that the economy is on the verge of another depression? (then again, some say its already here and I agree with that) 

That doesn't mean one should be complacent, but the majority were. There was low involvement with just COMMENTING on the petition. I know that several of the people that voiced active opposition to Kevin Zippel's stance in this thread who also wrote a letter, but just the low involvement shows how the hobby as a whole doesn't even care about itself. 

That also reminds me of the low involvement with the chytrid study by ASN. Zippel says he goes by data. Well, people had more than enough time to submit data and people didn't do it.

While I opposed the bill and wrote to the USFWS, I think Aark has done more for frogs than the hobby has.


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## SmackoftheGods (Jan 28, 2009)

Rain_Frog said:


> That also reminds me of the low involvement with the chytrid study by ASN. Zippel says he goes by data. Well, people had more than enough time to submit data and people didn't do it.


Big fat "THANKS" on that one!


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## Rain_Frog (Apr 27, 2004)

It is also sickening to see how much money is now tied up in the hobby, and how many people have started to view frogs as commodities instead of living creatures. If one kills a rare, endangered Mantella crocea, nobody seems to care because they are "cheap and disposable." There would be less uproar if something bad happened to a pair of Costa Rican auratus compared to a pair of histrionicus. Why? Money.

How many people still have wild caught imported almirante pumilio? How many of us have had frogs in our collection longer than 10 years? How many people have even been IN THE HOBBY that long? 

Yes, there are many responsible people out there. But the hobby as a whole-- that includes the random kid that buys a pet firebellied toad to end up killing it within two years-- has not been responsible. We can choose to BE responsible. How? Start getting INVOLVED. 

If we want to see more places testing for chytrid, start petitioning / writing to convince people to start doing it with faster turnaround times. But if people don't even care to even test to begin with-- evident with the study-- why should vets and people even spend money to offer the service if it won't be profitable?


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## billschwinn (Dec 17, 2008)

I would wholeheartedly agree the lack of comments from people on the site was appalling, yet people will raise hell about other things seemingly quite insignificant compared to what we could be facing from our govt.


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## johnc (Oct 9, 2009)

Rain_Frog said:


> Zippel says he goes by data. Well, people had more than enough time to submit data and people didn't do it.


Not that kind of data. He would listen to peer reviewed data, not hobbyist data. For that I don't blame him - it's the the way science works and ensures checks on itself.


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## Rain_Frog (Apr 27, 2004)

My point is that if the hobby as a whole doesn't start taking responsibility, our _privileges_ to keep frogs will be stripped from us-- that is already evident with frogs that dropped out of the hobby that one cannot get anymore.

Do you really think the majority of people-- the average teenagers that buy a clawed frog or fire bellied toad at the pet store-- are going to bleach the waste water to kill chytrid? Even myself I didn't start doing that until about a year ago.

If hobbyists are going to value the ability to keep a few pretty dart frogs that are listed as Least Concern over the entire ecosystem in North America, then why would AArk choose to support irresponsibility?

Perhaps it is time for the creation of a non profit organization (or maybe TWI can start it) or charitable service of testing animals for chytrid, so the hobby can start regulating itself. Do you WANT chytrid to wipe out your collection anyway? I know people that it HAS happened to-- entire collections gone.

Aark is working hard to protect what otherwise would be extinct now. We couldn't even keep aurantiaca breeding in sufficient numbers when they were imported by the THOUSANDS over the last decade.


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## JJuchems (Feb 16, 2004)

Rain_Frog said:


> Do you really think the government is going to spend even more money on just conserving frogs when the pet industry is growing, and taking in consideration that the economy is on the verge of another depression? (then again, some say it’ss already here and I agree with that)


Prohibition 1919-1930; Marijuana 1937 (Controlled Substance 1970); Chelonia under 4” 1975

These bans (of the top of my head) were all around or during economic down turn and turmoil. Let’s stay in the herpetocultural hobby. For example I do not necessary agree with a full repeal of the FDA Ban on turtles, but the repeal could add millions of dollars in state economies with turtle farms. Independent Turtle Farmers of Louisiana say estimate the sales could move from $8 million a year to $100 million. Louisiana has a state budget deficit of $319 million; new sources of revenue are deeply needed. So is the government willing to restrict a growing industry, yes. They have and they will. 


Rain_Frog said:


> It is also sickening to see how much money is now tied up in the hobby, and how many people have started to view frogs as commodities instead of living creatures. If one kills a rare, endangered Mantella crocea, nobody seems to care because they are "cheap and disposable." There would be less uproar if something bad happened to a pair of Costa Rican auratus compared to a pair of histrionicus. Why? Money.


You can’t have it both ways Doug. You start your augment defending the hobby as an economic interest and then defame the hobby as an economic interest. I don’t think or see any species as cheap and disposable. I would like to see baby turtles sales legalized. What I don’t want to see a missing tooth guy selling them for $10 at a flea market and trying to sell me an “original/vintage” IKE for President button for $50 that has “reproduction” labeled on the back. I have firsthand experience of this crap. I guess if money is an issue everyone should sell their frogs for $25-50, or better give them away. High prices help keep inexperienced keepers from owning rarer and harder to keep species. There are plenty of examples of WC “cheap” animals being available and increase prices get the hobby to take a real look and plan of action towards them. Money is what may save this hobby in many ways. 


Rain_Frog said:


> How many people still have wild caught imported almirante pumilio? How many of us have had frogs in our collection longer than 10 years? How many people have even been IN THE HOBBY that long?


I have been around for 10+yrs. This not just an amphibian issue but herpetculture and pet trade in general. The pet trade has thrived on impulse purchases of small mammals, avia, aquaria, and herps. They have tried to lose this stigma, but for many it is still part of the sales plan. 


Rain_Frog said:


> We can choose to BE responsible. How? Start getting INVOLVED.


And being involved mean more than just internet based groups, loosely formed meetings, and forums. Herpetological societies are dyeing across the country. Many of these groups have had political involvement and political members. Yes, that’s right members of congress as members. More groups needed to formally and legally organize. 


Rain_Frog said:


> If we want to see more places testing for chytrid, start petitioning / writing to convince people to start doing it with faster turnaround times. But if people don't even care to even test to begin with-- evident with the study-- why should vets and people even spend money to offer the service if it won't be profitable?


From what I understand this is not the issue why more labs are not completing the test. I maybe wrong, but if my memory is right it has to do with lad procedures being kept private.


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## Rain_Frog (Apr 27, 2004)

> You can’t have it both ways Doug. You start your augment defending the hobby as an economic interest and then defame the hobby as an economic interest.


Because of the economic, private interest is what allows hobbyists to breed animals and more species than a zoo can have budget for, but because it is an economic interest, it will be likely subject to trends. If people aren't going to buy one species of frog, there will be less incentative to breed it.



> I don’t think or see any species as cheap and disposable. I would like to see baby turtles sales legalized.


I never said you personally did-- but a lot of other people out there do, unfortunately. And this extends BEYOND dart frogs, mantellas, and tree frogs. Look what goes on at the local pet store. Like you said, the whole pet thing in general.



> I guess if money is an issue everyone should sell their frogs for $25-50, or better give them away.


i've started doing that for a lot of stuff, and also, stuff has been given to me for free from other people.



> High prices help keep inexperienced keepers from owning rarer and harder to keep species.


I remember about six years ago when ranitomeya species were becoming more popular. They were labeled as "intermediate or difficult" compared to the standard recommended beginner species; auratus, tinctorius, and leucomelas. But I know there were many people that bought them as their first dart frog despite they were classified as "difficult." 



> There are plenty of examples of WC “cheap” animals being available and increase prices get the hobby to take a real look and plan of action towards them. Money is what may save this hobby in many ways.


Things have worked the opposite for frogs that produce a high number of offspring like Mantella-- you have to compete with wild caught adult frogs that are offered for sale. You can't really predict what is going to popular one year and what will be the next. Unfortunately, its when things are NOT available wild caught when everyone wants them.

Jason, I respect you very much, and I hope you realize that I OPPOSED the petition. My point is that if the hobby doesn't start regulating itself better, somebody else will try to do it for us, and I am no fan of government takeover. 

It is true-- if we really value our frogs and want to continue keeping them, we're going to have to crack the whip at ourselves.


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## JJuchems (Feb 16, 2004)

Doug,
The respect is mutual and your work with Mantellas and dedication towards them is impeccable. 

Sorry Doug you were the target of my rant, many people seem to find to appalling that people make an income or economics play an interest in the hobby. Economics will play with trends, and their is little that can be done to reduce these trends. We live in an economy and society that supports trends. I remember in junior high Airwalk shoes where $75 and the it shoes, now they are Payless shoes. Herps as disposable pets is what fuels the pet trade and will in the end hurt herpetoculture. 

There are few fans of a governmental regulated hobby, but the arm is stretching and a group that is taking funding and actively soliciting funding from hobbyist needs to recognize, respect, and defend the hobby. Like it our not, don't ask for help and support if it is not mutual. As AArk said themselves, this hobby has established more than zoo's. 

I have also had a lot of free time recovering from stuff and hopped up on pain killers, so I need to pull my self from constant reading of the forums and watch a movie or something.


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## thedude (Nov 28, 2007)

markpulawski said:


> If everyone bags their dead frogs, that would be a good poll for someone to put up...what do you do with your deceased frogs??


i used to burn them, as i do with anything that comes from my frog room im getting rid of. aside from water, which i water the plants in the frog room with. now i put them in small bottles filled with 150 proof everclear. got the idea from a speech at microcosm.


On the note of supporting aark…absolutely. i still donate to defenders as well, mainly because of all the work they do helping wolves.

i think we should do a donation grant for them as well. in fact, my new years resolution is to give 5% of every frog i sell in 2011 to amphibian ark. hopefully that gets the ball rolling.


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## JJuchems (Feb 16, 2004)

thedude said:


> On the note of supporting aark…absolutely. i still donate to defenders as well, mainly because of all the work they do helping wolves.


Defenders link supports Save the Frogs!: Frog Facts and Video - Defenders of Wildlife

Bottom of page under " For additional information"


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