# Sticky  USF&WS Federal Listing (Chytrid-Free Certification)



## Web Wheeler

Here's the listing:



> [Federal Register: September 17, 2010 (Volume 75, Number 180)]
> [Proposed Rules]
> [Page 56975-56976]
> From the Federal Register Online via GPO Access [wais.access.gpo.gov]
> [DOCID:fr17se10-31]
> 
> =======================================================================
> -----------------------------------------------------------------------
> 
> DEPARTMENT OF THE INTERIOR
> 
> Fish and Wildlife Service
> 
> 50 CFR Part 16
> 
> [Docket No. FWS-R9-FHC-2009-0093; 94140-1342-0000-N5]
> RIN 1018-AX05
> 
> 
> Injurious Wildlife Species; Review of Information Concerning a
> Petition To List All Live Amphibians in Trade as Injurious Unless Free
> of Batrachochytrium dendrobatidis
> 
> AGENCY: Fish and Wildlife Service, Interior.
> 
> ACTION: Notice of inquiry.
> 
> -----------------------------------------------------------------------
> 
> SUMMARY: We, the U.S. Fish and Wildlife Service (Service), are
> reviewing a petition to list, under the Lacey Act, all live amphibians
> or their eggs in trade as injurious unless certified as free of
> Batrachochytrium dendrobatidis (chytrid fungus). The importation and
> introduction of live amphibians infected with chytrid fungus into the
> natural ecosystems of the United States may pose a threat to interests
> of agriculture, horticulture, forestry, or to wildlife or the wildlife
> resources of the United States. An injurious wildlife listing would
> prohibit the importation of live amphibians or their eggs infected with
> chytrid fungus into, or transportation between, States, the District of
> Columbia, the Commonwealth of Puerto Rico, or any territory or
> possession of the United States by any means, without a permit. We may
> issue permits for scientific, medical, educational, or zoological
> purposes. This document seeks information from the public to aid in
> determining if a proposed rule is warranted.
> 
> DATES: We will consider information received or postmarked on or before
> December 16, 2010.
> 
> ADDRESSES: You may submit comments by one of the following methods:
> Federal eRulemaking Portal: Regulations.gov.
> Follow the instructions for submitting comments to Docket No. FWS-R9-
> FHC-2009-0093.
> U.S. mail or hand-delivery: Public Comments Processing,
> Attn: Docket No. FWS-R9-FHC-2009-0093, Division of Policy and
> Directives Management, U.S. Fish and Wildlife Service, 4401 North
> Fairfax Drive, Suite 222, Arlington, VA 22203.
> 
> FOR FURTHER INFORMATION CONTACT: Susan Jewell, Branch of Aquatic
> Invasive Species, U.S. Fish and Wildlife Service, MS 770, 4401 N.
> Fairfax Drive, Arlington, VA 22203; telephone 703-358-2416. If you use
> a telecommunications device for the deaf (TDD), call the Federal
> Information Relay Service (FIRS) at 800-877-8339.
> 
> SUPPLEMENTARY INFORMATION: On September 9, 2009, Department of the
> Interior Secretary Ken Salazar received a petition from the Defenders
> of Wildlife requesting that live amphibians or their eggs in trade be
> considered for inclusion in the injurious wildlife regulations (50 CFR
> part 16) under the Lacey Act (18 U.S.C. 42) unless they are free of
> Batrachochytrium dendrobatidis (chytrid fungus). The Defenders of
> Wildlife is concerned that unregulated trade--primarily for pet use and
> as live animals for consumption as frog legs--continues to threaten the
> survival of many amphibian species, including domestic and foreign
> species listed by the Service under the Endangered Species Act of 1973
> as amended (ESA; 16 U.S.C. 1531 et seq.), candidate species, and other
> species.
> Specifically, the petition to Secretary Salazar proposes the
> following revision to the Service regulations at 50 CFR 16.14.
> 
> Importation of live amphibians or their eggs. All live
> amphibians and their eggs are prohibited entry into the United
> States, or to be exported from the United States, or transported in
> interstate commerce, for any purposes, except in compliance with
> this section. Upon the filing of a written declaration with the
> District Director of Customs at the port of entry as required under
> Sec. 14.61, species of live amphibians or their eggs may be
> imported, transported, and possessed in captivity only if the
> shipment complies with a certification and handling system that
> meets or exceeds recommendations of the World Organization for
> Animal Health in its Aquatic Animal Health Code on Batrachochytrium
> dendrobatidis. No such live amphibians or any progeny or eggs
> thereof may be released into the wild except by the State wildlife
> conservation agency having jurisdiction over the area of release or
> by persons having prior written permission for release from such
> agency. All live amphibians and their eggs are prohibited from
> interstate commerce in the United States and from export out of the
> United States unless in a shipment accompanied by a written
> declaration, in such form as the Director of the Fish and Wildlife
> Service shall provide, which
> 
> [[Page 56976]]
> 
> indicates the shipment meets or exceeds the recommendations of the
> World Organization for Animal Health in its Aquatic Animal Health
> Code on Batrachochytrium dendrobatidis.
> 
> We are seeking information on the importation and transportation of
> live amphibians or their eggs and chytrid fungus (also known as
> chytridiomycosis) for possible addition to the injurious wildlife list
> under the Lacey Act.
> The regulations contained in 50 CFR part 16 implement the Lacey
> Act. Under the terms of the injurious wildlife provisions of the Lacey
> Act, the Secretary of the Interior is authorized to prohibit the
> importation and interstate transportation of species designated by the
> Secretary as injurious. Injurious wildlife are those species,
> offspring, and eggs that are injurious or potentially injurious to
> wildlife or wildlife resources, to human beings, or to the interests of
> forestry, horticulture, or agriculture of the United States. Wild
> mammals, wild birds, fish, mollusks, crustaceans, amphibians, and
> reptiles are the only organisms that can be added to the injurious
> wildlife list. The lists of injurious wildlife are provided at 50 CFR
> 16.11-16.15. If the process initiated by this notice results in the
> addition of a species to the list of injurious wildlife contained in 50
> CFR part 16, their importation into or transportation between States,
> the District of Columbia, the Commonwealth of Puerto Rico, or any
> territory or possession of the United States would be prohibited,
> except by permit for zoological, educational, medical, or scientific
> purposes (in accordance with permit regulations at 50 CFR 16.22), or by
> Federal agencies without a permit solely for their own use.
> 
> Public Comments
> 
> This notice of inquiry requests biological, economic, or other data
> regarding the addition of live amphibians as injurious unless free of
> Batrachochytrium dendrobatidis (chytrid fungus) to the list of
> injurious wildlife. This information, along with other sources of data,
> will be used to determine if live amphibians or their eggs that are
> infected with Batrachochytrium dendrobatidis are a threat, or potential
> threat, to those interests of the United States delineated above, and
> thus warrant addition to the list of injurious wildlife in 50 CFR
> 16.14.
> You may submit your information and materials concerning this
> notice of inquiry by one of the methods listed in the ADDRESSES
> section. If you submit a comment via Regulations.gov, your
> entire comment, including any personal identifying information, will be
> posted on the Web site. If you submit a hardcopy comment that includes
> personal identifying information, you may request at the top of your
> document that we withhold this information from public review. However,
> we cannot guarantee that we will be able to do so. We will post all
> hardcopy comments on Regulations.gov.
> Comments and materials we receive, as well as supporting
> documentation we used in preparing this notice of inquiry, will be
> available for public inspection on Regulations.gov, or by
> appointment, during normal business hours, at the U.S. Fish and
> Wildlife Service, Room 770, 4401 North Fairfax Drive, Arlington, VA
> 22203.
> We are soliciting information and supporting data from the public
> to gain substantive information, and we specifically seek information
> on the following questions regarding the importation of live amphibians
> and their eggs infected with Batrachochytrium dendrobatidis (chytrid
> fungus):
> (1) What Federal, State, or tribal regulations exist to prevent the
> spread of chytrid fungus?
> (2) Are there any known mechanisms in the United States to test
> for, control, or regulate movement or interstate transport of chytrid
> fungus?
> (3) How many businesses import live amphibians or their eggs into
> the United States?
> (4) How many businesses sell live amphibians or their eggs for
> interstate commerce?
> (5) What are the annual sales of these imported live amphibians and
> their eggs?
> (6) What species of amphibians, fish, or other class of animal have
> been affected by chytrid fungus in the United States and how were they
> infected?
> (7) What are the current and potential effects to species listed as
> threatened or endangered under the ESA that are contaminated with
> chytrid fungus?
> (8) What are the potential costs of recovering threatened or
> endangered species affected by chytrid fungus?
> (9) What is the likelihood that wild amphibians would be affected
> by the importation of live amphibians or their eggs that harbor chytrid
> fungus?
> (10) What would it cost to eradicate chytrid fungus?
> (11) Are there any potential benefits to allowing the chytrid
> fungus pathogen to be imported?
> (12) What is the potential for the industries that conduct trade in
> amphibians to self-police through voluntary best practices; for
> example, how successful is the ``Bd-Free `Phibs Campaign'' sponsored by
> the Pet Industry Joint Advisory Council?
> (13) What peer-reviewed methods for detecting chytrid fungus have
> been published?
> (14) Are there any other comments or information regarding the
> listing of live amphibians as injurious unless free of chytrid fungus?
> 
> Dated: September 10, 2010.
> Thomas L. Strickland,
> Assistant Secretary for Fish and Wildlife and Parks.
> [FR Doc. 2010-23039 Filed 9-16-10; 8:45 am]
> BILLING CODE 4310-55-P
> 
> Source: Regulations.gov


Everyone needs to study this so we can figure out what it means. For example, I'm very concerned about this:



> If the process initiated by this notice results in the
> addition of a species to the list of injurious wildlife contained in 50
> CFR part 16, their importation into or transportation between States,
> the District of Columbia, the Commonwealth of Puerto Rico, or any
> territory or possession of the United States would be prohibited,
> *except by permit for zoological, educational, medical, or scientific
> purposes (in accordance with permit regulations at 50 CFR 16.22), or by
> Federal agencies without a permit solely for their own use*.
> 
> Emphasis in *bold* is mine (W.W.).


From my initial read of this, it seems like private individuals would NOT QUALIFY for a permit.

Understanding this listing is VERY IMPORTANT to us froggers! The first step in fighting this proposed listing (ban) is to understand what it says.

Comments please!!!


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## Catfur

As I understand the section you quoted, in conjunction with the other clauses. Private individuals, businesses, farms, etc... could import/transport amphibians as long as they were certified Chytrid free. Zoological, medical, etc... institutions would not be required to have amphibians certified as chytrid free in order to import/transport amphibians.

I am strongly concerned that "certified chytrid free" does not seem to be well defined. I see lots of potential for mischief in this clause.


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## skylsdale

The process by which animals would be certified as being chytrid free has not yet been developed. People need to realize that one of the primary reasons for this open comment period is for the USFWS to obtain input from various people and sectors in order to better inform the decision that must be made (and one must be made because a petition was legally presented to them).

So rather than freaking out and raging that "the man" is going to take away everyone's amphibians (as people have done in past threads), I believe energy would better be spent engaging the situation in a rational matter. TWI is preparing to submit our findings from the chytrid study we are doing so that the USFWS has some actual data regarding the presence of the fungus in captive collections of Dendrobatids (because, as of right now, there simply isn't any since no study of this sort has ever been done). I personally think that participating in something like this (in a way that produces and provides scientifically-based information and tangible knowledge) is more beneficial than the fearmongering that tends to eventually dominate discussions/issues like this.

Also, something to keep in mind: there are currently 7 known strains of Bd. The most virulent/deadly strains (that have decimated amphibian populations in Central and South America...where our Dendrobatids come from) have yet to be introduced into and/or appear in North America. So don't think that what's happening now to our native amphibians is the worst it's going to get...it could be MUCH worse. I would personally hate for this hobby (through the importation and/or trade of Bd-infected animals) to be a participant in the further spread of these strains into areas and amphibian populations that have previously been uninfected by them.


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## fleshfrombone

Speaking of the study could I be provided with the written survey that came with the kits? I filled it out before i received and swabbed the new frogs.


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## skylsdale

Contact Mike K (Corpus Callosum) or Christina Hanson and they can get you another copy of the survey.


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## Catfur

skylsdale said:


> The process by which animals would be certified as being chytrid free has not yet been developed. People need to realize that one of the primary reasons for this open comment period is for the USFWS to obtain input from various people and sectors in order to better inform the decision that must be made (and one must be made because a petition was legally presented to them).
> 
> So rather than freaking out and raging that "the man" is going to take away everyone's amphibians (as people have done in past threads), I believe energy would better be spent engaging the situation in a rational matter.


The process of certifying animals as Chytrid free is, however, the ENTIRE guts of the measure. ALL the relevant restrictions, rules, whatnot spring forth from this unidentified process. Without some framework on this process, the entire thing is just a shell game.


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## fleshfrombone

Done, thanks Ron.


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## skylsdale

Catfur said:


> The process of certifying animals as Chytrid free is, however, the ENTIRE guts of the measure. ALL the relevant restrictions, rules, whatnot spring forth from this unidentified process. Without some framework on this process, the entire thing is just a shell game.


And without actual information and reliable data, they can't make the best possible decision or create a decent form of certification.

One of the problems is that zealots keep trying to turn this into a purely black/white issue, where the only option other than no certification is complete lockdown and confiscation of all amphibians from hobbyists. There are numerous ways in which a certification system could work--some of them may be needlessly complicated, but some of them could be highly effective and prevent populations of native North American amphibians from being infected with new (to the continent) strains of Bd. 

People seem to think that crying "THIS ISN'T FAIR!" on a forum _ad naseum_ is somehow going to affect or impact things, as if the USFWS is reading these threads with baited breath in order to figure out which step to take next. If people are worried about the process of certification they should do something to help inform the creation of that process, or provide information to help the USFWS determine if such a process is even warranted. 

Simply complaining about it and/or working people into a froth over the issue does neither.


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## Web Wheeler

As per this directive:



> Upon the filing of a written declaration with the District Director of Customs at the port of entry as required under Sec. 14.61, species of live amphibians or their eggs may be imported, transported, and possessed in captivity only if the shipment complies with a certification and handling system that meets or exceeds recommendations of the World Organization for Animal Health in its Aquatic Animal Health Code on Batrachochytrium dendrobatidis.


Here's a link to the World Organization for Animal Health in its Aquatic Animal Health Code on Batrachochytrium dendrobatidis.

Additionally:



> All live amphibians and their eggs are prohibited from interstate commerce in the United States and from export out of the United States unless in a shipment accompanied by a written declaration, in such form as the Director of the Fish and Wildlife Service shall provide, which indicates the shipment meets or exceeds the recommendations of the World Organization for Animal Health in its Aquatic Animal Health Code on Batrachochytrium dendrobatidis.


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## Ed

skylsdale said:


> And without actual information and reliable data, they can't make the best possible decision or create a decent form of certification.
> 
> One of the problems is that zealots keep trying to turn this into a purely black/white issue, where the only option other than no certification is complete lockdown and confiscation of all amphibians from hobbyists. There are numerous ways in which a certification system could work--some of them may be needlessly complicated, but some of them could be highly effective and prevent populations of native North American amphibians from being infected with new (to the continent) strains of Bd.
> 
> People seem to think that crying "THIS ISN'T FAIR!" on a forum _ad naseum_ is somehow going to affect or impact things, as if the USFWS is reading these threads with baited breath in order to figure out which step to take next. If people are worried about the process of certification they should do something to help inform the creation of that process, or provide information to help the USFWS determine if such a process is even warranted.
> 
> Simply complaining about it and/or working people into a froth over the issue does neither.


It should also be noted that even if this is passed USF&W are not going to be confiscating amphibians from the hobbyist's home. That is outside of the jurisdiction of the rule change. It would require further legislation on the part of the hobbyists home state...


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## Ed

Web Wheeler said:


> As per this directive:
> 
> 
> 
> Here's a link to the World Organization for Animal Health in its Aquatic Animal Health Code on Batrachochytrium dendrobatidis.
> 
> Assuming that is the final language used....Under that language, you would simply need a certificate from a vet stating that the eggs/larva/animals stating that they were healthy and free of the disease.
> If the animals are being imported they need a certificate from a vet stating that the animals were treated for Bd and are healthy for export. (see Article 8.1.10 in the linked info..)
> 
> This is also clear under the definition of competant authority in the linked document Quote"Competent Authority
> 
> means the Veterinary Authority or other Governmental Authority of a Member having the responsibility and competence for ensuring or supervising the implementation of aquatic animal health and welfare measures, international health certification and other standards and recommendations in the Aquatic Code in the whole territory."endquote.
> 
> Ed


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## Web Wheeler

Ed said:


> means the Veterinary Authority or other Governmental Authority of a Member having the responsibility and competence for ensuring or supervising the implementation of aquatic animal health and welfare measures, international health certification and other standards and recommendations in the Aquatic Code in the whole territory.
> 
> Ed


Yes, but I'm not sure that would be just any veterinarian, as the directive states "in the whole territory". And, if you look up "Veterinary Authority", you get:



> means the Governmental Authority of an OIE Member, comprising veterinarians, other professionals and para-professionals, having the responsibility and competence for ensuring or supervising the implementation of aquatic animal health and welfare measures, international aquatic animal health certification and other standards and recommendations in the Aquatic Code in the whole territory.


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## Ed

Web Wheeler said:


> Yes, but I'm not sure that would be just any veterinarian, as the directive states "in the whole territory". And, if you look up "Veterinary Authority", you get:


I think this is overreaching the language as that permit was written for country to country transport... in that case, you would be dealing with the goverment vet. Inside the US, it is way to premature to assume that they are going to require the state vet to provide the certification as this would swamp and bury the state vet with work far in excess of thier ability to handle. Zoos have actually been already following this standard for animal shipments for a number of years and they do not use the state vets. Instead they use the vet contracted to work for the Zoo who fills out a health certificate which is included in the shipment. 


Ed


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## billschwinn

So if I understand the possible outcome, would each frog need the vet check, which would be costly and time consuming to a breeder, probably cost prohibitive would be a better description. Or a vet screening the breeders entire collection and as long as nothing new is added it could be labled as clean? I think the latter would be more appropriate and more feasable.


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## Web Wheeler

Here are some questions that need answers:

1. Who qualifies for the certification?

2. Who will perform the certification?

3. How will the certification be conducted?

4. How much will the certification cost?

5. How long will the certification take?

6. How often does the certification have to be done?

7. Where will the certification take place?


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## Ed

billschwinn said:


> So if I understand the possible outcome, would each frog need the vet check, which would be costly and time consuming to a breeder, probably cost prohibitive would be a better description. Or a vet screening the breeders entire collection and as long as nothing new is added it could be labled as clean? I think the latter would be more appropriate and more feasable.


None of this is listed in the actual regulation as it hasn't been established yet. The filing of the petition requested that WHO standard be used but that has not been *established as the final format that will be used*. 
Even if that format is established, there is language in the permit to establish a facility that is negative for chytrid. A full step by step was not outlined in the World Health Organization requirement (as that is up to the country in question as long as the vet is willing to certifies it as negative...). 

This is what the comment period is intended to help figure out. If people want thier comments to be heard, then they need to be reasonable and to the point. If you rant and rave, your comment will be discounted. 

People should also keep in mind that this will do nothing to the trade in amphibians within a state as within state transactions and transport is outside of the jurisdiction of USF&W.


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## Ed

Web Wheeler said:


> Here are some questions that need answers:
> 
> 1. Who qualifies for the certification?
> 
> 2. Who will perform the certification?
> 
> 3. How will the certification be conducted?
> 
> 4. How much will the certification cost?
> 
> 5. How long will the certification take?
> 
> 6. How often does the certification have to be done?
> 
> 7. Where will the certification take place?


And these will be developed based on the comments recieved. They cannot be answered yet as the regulations for them have not been established as of yet, the comment period is so they can establish them...... if you want them answered then reasonable suggestions should be made to the USF&W.


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## billschwinn

It should be noted that many sales are done in states where the breeders are not. In other words interstate shipping is extremely important in this hobby/business.Therefore I think an informed and realistic person would find stopping interstate shipping would be very bad .We have an administration in office that has a record of sweeping changes without regard to what rational people think.I feel we cant be too careful and complacent with what is at hand.


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## Ed

billschwinn said:


> It should be noted that many sales are done in states where the breeders are not. In other words interstate shipping is extremely important in this hobby/business.Therefore I think an informed and realistic person would find stopping interstate shipping would be very bad .We have an administration in office that has a record of sweeping changes without regard to what rational people think.I feel we cant be too careful and complacent with what is at hand.


The entire review process for the proposal is to deal with interstate and intercountry transfer of amphibians. If you are a breeder who sells across state lines, then letting them know how much of your declared income is made via amphibians and how this will affect you if you are prohibited from shipping is a good idea...

Ed


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## Web Wheeler

Ed said:


> And these will be developed based on the comments recieved. They cannot be answered yet as the regulations for them have not been established as of yet, the comment period is so they can establish them...... if you want them answered then reasonable suggestions should be made to the USF&W.


Without knowing the answers to the questions I've posted, it's hard to say how an individual should respond to the USF&WS request for comments. For example, I'm sure that everyone here is in favour of things that will curtail the spread of Chytrid fungus, however, the answers to the questions I've posted will largely determine the reasonableness of the proposal. So, in my opinion, we do need answers to make an informed comment.


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## Ed

Web Wheeler said:


> Without knowing the answers to the questions I've posted, it's hard to say how an individual should respond to the USF&WS request for comments. For example, I'm sure that everyone here is in favour of things that will curtail the spread of Chytrid fungus, however, the answers to the questions I've posted will largely determine the reasonableness of the proposal. So, in my opinion, we do need answers to make an informed comment.


Then you will be waiting for to make comments once they finalize the proposal.


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## Web Wheeler

Ed said:


> Then you will be waiting for to make comments once they finalize the proposal.


USARK is aware of the Defenders of Wildlife petition and the subsequent proposal by USF&WS. I expect USARK will have something to say about this before the comment period ends. That's what I'll be waiting for. In the meantime, I intend to find out as much info as I can. In my opinion, others should also do the same.

P.S. I also expect PIJAC to chime in on this and to comment on the USF&WS proposal.


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## Ed

Make suggestions for what they could be.. that is being proactive. 

A simple suggestion for this could be (and I'm being hypothetical and not arguing from a specific position)

could be as follows 

1) anyone who engages in captive breeding who sells across state lines

2) any veterinarian who is willing to review the test results and waste treatment control... 

3) testing of each enclosure of the amphibians (there is no scientific need to test all animals in an enclosure as if one has it the probability is they all will) by pcr swab. 

4) permit costs are up to the goverment. The costs of a running a pcr swab to test for chytrid are coming down as more labs get into the mix. Currently it costs @ $15 to run a test. What does it cost for a captive bred wildlife permit? In that case you have to get a permit for each animal you are shipping across a state border in this case you would be getting one permit per batch of animals... 

5) however long it takes for the test to get run, and the permit to be processed.. how long do any other permits take? On what basis would you assume that this permit would take more or less time than any other permit? 

6) This is up for suggestions.. A reasonable suggestion could be anywhere from once a year to once every five years ... suggestions can be made for new animals added to a collection.. for example from a "clean" operation, then no testing is needed.. if from a non-certified source then quarantine and testing is needed to keep certification. 

7) Certification is obviously going to be in several places as it will require lab results... where the results are reviewed and signed off on.... there is no obvious need for a home visit unless you are a major aquaculture facility... 

Instead of throwing questions out there and complaining that you can't make any suggestions unless you know what the final results are going to be ahead of time, be proactive and make constructive suggestions.


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## Ed

Web Wheeler said:


> USARK is aware of the Defenders of Wildlife petition and the subsequent proposal by USF&WS. I expect USARK will have something to say about this before the comment period ends. That's what I'll be waiting for. In the meantime, I intend to find out as much info as I can. In my opinion, others should also do the same.
> 
> P.S. I also expect PIJAC to chime in on this and to comment on the USF&WS proposal.


If you are waiting for USARK to comment then why are you saying you have to have those questions answered before you can make a comment? Are you expecting USARK to provide those answers before USF&W finalizes the report? 

Ed


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## Web Wheeler

Ed said:


> If you are waiting for USARK to comment then why are you saying you have to have those questions answered before you can make a comment? Are you expecting USARK to provide those answers before USF&W finalizes the report?
> 
> Ed


I'll wait and see what USARK and PIJAC have to say about this proposal by USF&WS, but I would hope that many of my questions will be answered before the comment period ends. In that way I can make a more informed comment as I will better understand how the proposal will affect me. In either case, I intend to be as informed as possible.


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## skylsdale

Ed said:


> Instead of throwing questions out there and complaining that you can't make any suggestions unless you know what the final results are going to be ahead of time, be proactive and make constructive suggestions.


I'm becoming more and more convinced that people aren't actually aware of what this process actually entails and what the purpose of the comment period is. It seems to me as though people are waiting for some edict that they can then protest against...and their assumption is that they can't have any say in the forming of said edict. The exact opposite is in fact true: the purpose of this open comment period (which is required by law) is for people to actually inform and shape and therefore helping to create (or at least influence) the resulting policy.


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## Web Wheeler

skylsdale said:


> I'm becoming more and more convinced that people aren't actually aware of what this process actually entails and what the purpose of the comment period is. It seems to me as though people are waiting for some edict that they can then protest against...and their assumption is that they can't have any say in the forming of said edict. The exact opposite is in fact true: the purpose of this open comment period (which is required by law) is for people to actually inform and shape and therefore helping to create (or at least influence) the resulting policy.


One can form a perspective on the listing by USF&WS by considering what information the USF&WS would like to know. Specifically:



> (1) What Federal, State, or tribal regulations exist to prevent the spread of chytrid fungus?
> (2) Are there any known mechanisms in the United States to test for, control, or regulate movement or interstate transport of chytrid fungus?
> (3) How many businesses import live amphibians or their eggs into the United States?
> (4) How many businesses sell live amphibians or their eggs for interstate commerce?
> (5) What are the annual sales of these imported live amphibians and their eggs?
> (6) What species of amphibians, fish, or other class of animal have been affected by chytrid fungus in the United States and how were they infected?
> (7) What are the current and potential effects to species listed as threatened or endangered under the ESA that are contaminated with chytrid fungus?
> (8) What are the potential costs of recovering threatened or endangered species affected by chytrid fungus?
> (9) What is the likelihood that wild amphibians would be affected by the importation of live amphibians or their eggs that harbor chytrid fungus?
> (10) What would it cost to eradicate chytrid fungus?
> (11) Are there any potential benefits to allowing the chytrid fungus pathogen to be imported?
> (12) What is the potential for the industries that conduct trade in amphibians to self-police through voluntary best practices; for example, how successful is the ``Bd-Free `Phibs Campaign'' sponsored by the Pet Industry Joint Advisory Council?
> (13) What peer-reviewed methods for detecting chytrid fungus have been published?
> (14) Are there any other comments or information regarding the listing of live amphibians as injurious unless free of chytrid fungus?


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## Michael Shrom

Many comments will be posted on line when made to USFW where anybody can read. I plan on studying the issue a little more and reading some responses and comments before making my comment to USFW. We have about 3 months to comment. I do have a quick reaction but don't want to go off half cocked.

Half cocked reaction. When I took 5 salamanders to a local vet to have them certified healthy to ship to New Mexico he looked at them and said "they look good." He charged me 50.00 for just picking the group up and looking at them. What do you suppose he would charge for testing 1000 axolotls for chytrid either in large batches or small groups as they are shipped out?


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## SethDoty

Michael Shrom said:


> Half cocked reaction. When I took 5 salamanders to a local vet to have them certified healthy to ship to New Mexico he looked at them and said "they look good." He charged me 50.00 for just picking the group up and looking at them. What do you suppose he would charge for testing 1000 axolotls for chytrid either in large batches or small groups as they are shipped out?


An that is the sad truth. Realistically testing would very likely either be so inefficient that it would just be a total waste of time and money or cost prohibitive. Of course the real goal of "defenders of wildlife" is to shut down the trade. That is where their real interest is. They are almost as bad as peta in that respect. Amphibian keepers should think it through very carefully before agreeing to a compromise on anything they propose.


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## billschwinn

I agree with Seth Doty.


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## Tony

skylsdale said:


> I'm becoming more and more convinced that people aren't actually aware of what this process actually entails and what the purpose of the comment period is. It seems to me as though people are waiting for some edict that they can then protest against...and their assumption is that they can't have any say in the forming of said edict. The exact opposite is in fact true: the purpose of this open comment period (which is required by law) is for people to actually inform and shape and therefore helping to create (or at least influence) the resulting policy.


Like we were able to shape and inform the attempted snake bans?


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## skylsdale

Michael Shrom said:


> What do you suppose he would charge for testing 1000 axolotls for chytrid either in large batches or small groups as they are shipped out?


Assuming they were all raised together and/or in the same facility...the protocol may require that you just have a single animal or two tested for Bd and they would serve as representatives for the entire group. Talking to folks who have worked in the import/export system, it seems as though this would be the most feasible system.

So maybe $35 for the lab fee, plus whatever the swab and test tube cost...maybe fees for the permits. Theoretically it could cost around the same amount to have your entire group of animals cleared for interestate shipping as it did for you to take a few into the vet and have him look at them.

But again, we don't have enough specifics at this point to do much more than speculate...but we need to keep in mind that for every ridiculous cost, fee, procedure there could be a somewhat logical, affordable one as well.


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## fleshfrombone

billschwinn said:


> It should be noted that many sales are done in states where the breeders are not. In other words interstate shipping is extremely important in this hobby/business.Therefore I think an informed and realistic person would find stopping interstate shipping would be very bad .We have an administration in office that has a record of sweeping changes without regard to what rational people think.I feel we cant be too careful and complacent with what is at hand.


Don't get me started on the Obama administration.


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## skylsdale

SethDoty said:


> Amphibian keepers should think it through very carefully before agreeing to a compromise on anything they propose.


As an amphibian keeper, I am well aware of DOW's intent...but as a fan of wild amphibians, I am also well aware the impact more virulent strains of chytrid could have on populations of native amphibians here in North America.


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## Web Wheeler

skylsdale said:


> As an amphibian keeper, I am well aware of DOW's intent...but as a fan of wild amphibians, I am also well aware the impact more virulent strains of chytrid could have on populations of native amphibians here in North America.


Then you would have to have a way to stop the spread of amphibians coming into the U.S. on produce and ornamental plants. Funny, there's no mention of this in the DOW Petition or from USF&WS.

Furthermore, there's a good possibility that Chytrid can survive in bird feathers:



> Amphibian chytridiomycosis caused by Batrachochytrium dendrobatidis has spread at an alarming rate over large distances throughout sensitive frog populations in eastern Australia, Central America and New Zealand. Infected amphibians and contaminated water are implicated in translocation, but other vectors are unknown. Through in vitro studies we show that potential means of translocation may be moist soil and bird feathers. B. dendrobatidis survived for up to 3 mo in sterile, moist river sand with no other nutrients added. B. dendrobatidis attached to and grew on sterile feathers and were able to be transported by feathers to establish new cultures in media, surviving between 1 and 3 h of drying between transfers. If these in vitro results are valid in the natural environment, the findings raise the possibilities that B. dendrobatidis may be translocated by movement of moist river sand and that birds may carry the amphibian chytrid between frog habitats. However, further studies using sand and feathers containing normal microflora are essential.
> 
> Source: Possible modes of dissemination of the amphibian c... [Dis Aquat Organ. 2005] - PubMed result


There's also the possibility that Chytrid may be unstoppable, and if that's the case, then possibly there has never been a more urgent need for captive breeding of all sorts of amphibians. Thus, this regulation could actually lead to even more extinctions by discouraging captive breeding.

In my opinion, education would do far more good than regulation ever could.


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## skylsdale

> ...and if that's the case, then possibly there has never been a more urgent need for captive breeding of all sorts of amphibians.


I would agree with this statement, but probably not in the way you meant it. In regard to what the vast majority of hobbyists are keeping in their collections, those animals have little-to-no value in relationship to their wild counterparts...at least the way things are currently being done in the hobby (which has been discussed HERE and in other threads). Unless you're currently working with the Wyoming Toad? Chiricahua leopard frogs? Mountain yellow-legged frogs? 



> Thus, this regulation could actually lead to even more extinctions by discouraging captive breeding.


Not really, since the vast majority of amphibians in our care aren't really endangered in the wild...so our collections of pumilio, auratus, imitator, etc. wouldn't contribute at all to any "extinctions" (actually, relieving collection pressures on the wild Dendrobatid populations could actually result in a net benefit for many of the species/populations we keep).


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## Web Wheeler

Ron, are you speaking for the Dart Frog community or the amphibian keeping community in general? I was speaking for the latter as the listing by USF&WS would affect all amphibians.

Also, while Dart Frogs, such as pumilio, auratus, imitator, etc., may not be endangered today because of Chytrid, that could change, could it not? Additionally, would you agree that experience gained keeping *common* amphibians could contribute to the keeping of endangered amphibians?


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## skylsdale

No, I absolutely agree that keeping "common" amphibians could greatly contribute to the keeping of endangered amphibians--there is no argument there whatsoever. What I usually hear people say, however, is that by keeping their auratus they are helping preserve that species/population/morph in case it ever goes extinct in the wild. That is simply a misguided notion.

I also agree that DOW are missing large possible vectors of chytrid spreading and specifically targeting the hobby sector and are most likely just trying to get it shut down or minimized. However, I also don't agree that the hobby is doing everything it can to minimize the actual ways through which it could introduce Bd not only to non-infected captive animals, but also to wild native populations and ecosystems (through lack of proper water treatment from enclosures that might have chytrid infected frogs, etc.) and I think we should be open to not only considering that, but hopefully willing to do something to improve it.


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## Web Wheeler

skylsdale said:


> However, I also don't agree that the hobby is doing everything it can to minimize the actual ways through which it could introduce Bd not only to non-infected captive animals, but also to wild native populations and ecosystems (through lack of proper water treatment from enclosures that might have chytrid infected frogs, etc.) and I think we should be open to not only considering that, but hopefully willing to do something to improve it.


I agree 100% with you on this point, but I don't believe the proposed USF&WS regulation is the way to go. In my opinion, education would do far more good than regulation ever could.


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## savethefrogs

Chytridiomycosis is responsible for amphibian extinctions worldwide and the chytrid fungus has now been detected on over 385 amphibian species. An abundance of scientific data demonstrates that the amphibian pet, food, laboratory and bait industries drive the spread of this disease. Simple logic also supports this viewpoint: Over 100 million amphibians are shipped around the world each year. With such a staggering number, it is absolutely inevitable that sick imported amphibians (or the water in which they were held) will enter the environment outside their native ranges. History demonstrates that local or global species extinction is likely to follow the introduction of chytrid fungus, and there is currently no known way to eradicate chytrid fungus or ANY other amphibian disease from wild populations.

As such, SAVE THE FROGS! supports regulating the intercontinental trade and transport of amphibians. The proposed USFWS regulations (which are in alignment with the recommendation of the OIE World Organization for Animal Health) would be in the best interest of America's remaining amphibian populations. To be clear, without such regulations, we should assume that chytrid will continue to decimate America's remaining amphibian populations. It should be noted that there are many strains of chytrid fungus; even if an amphibian population has survived an initial epidemic wave and then acquired some resistance to the fungus, the population may not be resistant to future chytrid introductions. Thus keeping chytrid from being introduced into already affected regions is extremely important.

It is the responsibility of the pet, food, bait and laboratory industries to prove their amphibians are disease free, rather than the responsibility of amphibians to attempt to survive on a planet that humans have covered in lethal pathogens. 

With regard to economics, I would think that every USA captive breeder would be enthused by this proposal, as it would lead to a decline in the import of wild frogs, and those importers are your financial competition. With regards to the economic effect on the importers and distributors of wild frogs: it is thoroughly unethical to take any animal from its home without its consent, and to sever that animal's ability to return to its home. 

As for cost of tests, please see my paper:
Kriger, K.M., Hero, J.-M. and Ashton, K.J. (2006) Cost efficiency in the detection of chytridiomycosis using PCR assay. Diseases of Aquatic Organisms 71:149-154

I have analyzed over 3,000 chytrid samples and I would guess that a person with a qPCR machine (which is not cheap) could run samples at $5 each. I am sure there are some technologically-inclined people in the breeding community who could start a business out of testing samples if need be. I am also open to the possibility of teaching a chytrid detection class to interested parties, as I have done at the Smithsonian Tropical Research Institute. SAVE THE FROGS! currently provides a 100% free, detailed protocol for the detection of chytrid fungus by quantitative PCR, the most advanced and trustworthy method of detecting the fungus.

With regards to the statements previously posted that education is better than regulation: as the executive director of the world's leading amphibian conservation and education organization, I feel quite certain that education by itself is NOT sufficient to stop the extinction of amphibian species due to the chytrid fungus. For instance, how many people reading this thread are educated about the potential damage that chytrid can cause? I think most people. Yet how many people are willing to change their ways to accept the implications of that knowledge? It seems as though there are not many, unfortunately.

The frogs come first. Please show your support for the frogs by letting the USFWS know you support their proposal to list amphibians as injurious wildlife UNLESS & UNTIL they are shown to be free of disease. Then focus your energies on improving disease testing methods; lowering the cost of testing; and educating breeders, distributors and consumers about ways to minimize risk of disease transfer. 

More info:
Chytrid Fungus
Chytrid Fungus, Amphibians & the Lacey Act

Finally, please go sign up for the free SAVE THE FROGS! electronic newsletter, which I write.

Sincerely,
Kerry Kriger, Ph.D.
Save The Frogs - Founder, Executive Director, Ecologist

Save The Frogs is America's first and only public charity dedicated to amphibian conservation. Our mission is to protect amphibian populations and to promote a society that respects and appreciates
nature and wildlife.


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## Tony

I can't support regulations that would destroy the ability of private citizens to breed and distribute frogs. Your heart may be in the right place, but attacking the people who care most about amphibian conservation is not a productive strategy.


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## savethefrogs

Hi Tony,
The people who care most about amphibians are those who are willing to sacrifice their own personal interests for the betterment of the amphibians. 

It will not be possible to save the frogs if people rate their own personal needs over those of the frogs. There are simply too many humans, and too many threats to frogs.

Humans are not rapidly becoming extinct. Frogs are.
Kerry


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## Tony

savethefrogs said:


> Hi Tony,
> The people who care most about amphibians are those who are willing to sacrifice their own personal interests for the betterment of the amphibians.
> 
> It will not be possible to save the frogs if people rate their own personal needs over those of the frogs. There are simply too many humans, and too many threats to frogs.
> 
> Humans are not rapidly becoming extinct. Frogs are.
> Kerry


Destroying the amphibian hobby will not stop chytrid, habitat destruction, pollution, climate change, or most other threats to frogs in the wild. What it would do is destroy most of the captive bloodlines while leaving wild frogs to perish. I would rather see frogs in captivity than in picture books of extinct animals. Just think of what may have been if _Bufo periglenes_ had been established in captivity rather than being "protected" in Monteverde...


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## Tony

savethefrogs said:


> Save The Frogs is America's first and only public charity dedicated to amphibian conservation.


Being a member of this forum you must be aware of Tree Walkers International, why make the false claim of being the only public charity dedicated to amphibian conservation?


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## savethefrogs

Hi Tony,
Treewalkers, whose work I find valuable, is a nonprofit, but not a public charity. They are "a Project of Social and Environmental Entrepreneurs (SEE), a registered public charity, which provides non-profit status".

With regards to your statement about captive breeding being destroyed by the proposal, I find it a little far-fetched to think the proposal would destroy the trade. Why is it so hard to pass the $5-$10 cost of the diagnostic test on to the consumer? Why does the consumer deserve a pet frog if they aren't willing to spend an extra half hour's wage on its purchase?

Kerry


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## Tony

savethefrogs said:


> Hi Tony,
> Treewalkers, whose work I find valuable, is a nonprofit, but not a public charity. They are "a Project of Social and Environmental Entrepreneurs (SEE), a registered public charity, which provides non-profit status".


So semantics are more important than a group that is actually trying to do something constructive for amphibian conservation? Gotcha.



savethefrogs said:


> With regards to your statement about captive breeding being destroyed by the proposal, I find it a little far-fetched to think the proposal would destroy the trade. Why is it so hard to pass the $5-$10 cost of the diagnostic test on to the consumer? Why does the consumer deserve a pet frog if they aren't willing to spend an extra half hour's wage on its purchase?
> 
> Kerry


Because it costs way more than that and does nothing to stop real threats against wild amphibians. Why don't you address the other points in my post? Private collections hold vast numbers of threatened and endangered species, how exactly will destroying those bloodlines while their wild counterparts march toward extinction accomplish anything good?


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## Tony

Also, just so that nobody here falls for your game, here are a few quotes from your paper _Chytridiomycosis, Amphibian Extinctions, and Lessons for the Prevention of Future Panzootics_:



> *Unlike zoos and laboratories, whose conservation services
> render the translocation of amphibians an occasional
> necessity, the amphibian pet and bait trades are for the
> large part disposable, that is, they are unnecessary, serving
> little benefit to society. Their nearly complete dismantling
> would benefit amphibian populations...*


and:



> *The immediate implementation and enforcement of appropriate biosecurity measures, including a virtually complete ban on all unnecessary long-distance trade and transport of live amphibians, should be the highest priority for the scientific and legislative communities.*


You are a radical animal rights activist masquerading as a conservationist in your attempt to eliminate the amphibian hobby, no better than groups like Defenders of Wildlife, PETA and HSUS.


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## savethefrogs

Hi Tony,
To the extent that spending my days saving frogs from their permanent extinction is radical, I suppose you could classify me as such. As former Virginia Governor Tim Kaine stated when he legally recognized Save The Frogs Day last year, 'children have the right to see, hear and catch amphibians in their native habitat'. That is the end that SAVE THE FROGS! seeks. 

With regards to your TWI statement about semantics, you brought it up, and I correctly and thoroughly answered your question, so I do not see why you are still attempting to make me look as if I did something wrong or unethical, as I did neither. What you take to be semantics is actually a well-established legal difference.

You still have yet to provide any rationale for how the additional price of a diagnostic test will lead to the demise of the industry. As I said, a test can be done for as little as $5. I know because I have run 3,000 plus samples with my own hands. 

Lest you think that the focus of SAVE THE FROGS! is on pet trade issues, please have a look at our website. We have a variety of campaigns and programs covering a wide range of amphibian issues. If you feel the pet trade is being singled out among the 4 major amphibian trades (pet, food, lab and bait), you are incorrect. You may be especially interested in our frog legs campaign: The Problem With Frog Legs
We have also begun a campaign to end dissections, as that trade also contributes to the spread of harmful infectious diseases. 

The bloodlines of which you speak are nice to have, though I haven't seen many (any?) examples put forth about how captive pets have been used to conserve wild amphibian populations. Nor have I seen any information on how the trade in amphibians for use as pets has caused a reduction in the spread of harmful infectious diseases.

Finally, remember the math:
100 million amphibians being shipped around the world each year. Some captive populations have 60% prevalence of chytrid. What are the chances that no sick amphibian or the water in which a sick amphibian was held will escape into the environment in the next 100 years at current trade volumes and with no mandatory disease testing? I think less than 0.00000001% chance.

Batrachochytrium dendrobatidis was first isolated from a captive dendrobatid. Let's make sure captive frogs don't spread disease to wild populations.
Kerry


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## Tony

savethefrogs said:


> Hi Tony,
> To the extent that spending my days saving frogs from their permanent extinction is radical, I suppose you could classify me as such. As former Virginia Governor Tim Kaine stated when he legally recognized Save The Frogs Day last year, 'children have the right to see, hear and catch amphibians in their native habitat'. That is the end that SAVE THE FROGS! seeks.


And how does outlawing private ownership of amphibians stop chytrid, habitat destruction, pollution, climate change, or most other threats to frogs in the wild? Trying to stop chytrid by outlawing frogs after the disease is already established is silly and does nothing to stop the other serious threats.



savethefrogs said:


> With regards to your TWI statement about semantics, you brought it up, and I correctly and thoroughly answered your question, so I do not see why you are still attempting to make me look as if I did something wrong or unethical, as I did neither. What you take to be semantics is actually a well-established legal difference.


I was not aware of the distinction, fair enough. Your organization is still acting in a way that endangers amphibians, contrary to its supposed purpose.



savethefrogs said:


> You still have yet to provide any rationale for how the additional price of a diagnostic test will lead to the demise of the industry. As I said, a test can be done for as little as $5. I know because I have run 3,000 plus samples with my own hands.


Your stated goal is to end the pet trade, allowing this regulation would do nothing to stop the spread of chytrid while giving groups like yours a foot in the door to a full ban.



savethefrogs said:


> Lest you think that the focus of SAVE THE FROGS! is on pet trade issues, please have a look at our website. We have a variety of campaigns and programs covering a wide range of amphibian issues. If you feel the pet trade is being singled out among the 4 major amphibian trades (pet, food, lab and bait), you are incorrect. You may be especially interested in our frog legs campaign: The Problem With Frog Legs
> We have also begun a campaign to end dissections, as that trade also contributes to the spread of harmful infectious diseases.


The other facets of your campaign may have merit, but I will save my support for an organization that does not take my money with one hand while stabbing me in the back with the other. Your deceptive campaign for support is no better than the HSUS commercials that trick pet owners into supporting an agenda against pet owners while pretending that their donations support shelters.



savethefrogs said:


> The bloodlines of which you speak are nice to have, though I haven't seen many (any?) examples put forth about how captive pets have been used to conserve wild amphibian populations. Nor have I seen any information on how the trade in amphibians for use as pets has caused a reduction in the spread of harmful infectious diseases.


Captive pets may not directly support wild populations, but they do support the species as a whole. Wild populations of many species are going to disappear and there is nothing we can do about it. Is it better to have only pictures of _Agalychnis annae_ instead of the population thriving under the care of myself and other dedicated hobbyists? Should _Atelopus zeteki_ have been left to perish in the wild instead of being moved to captive breeding facilities? Is it really better that _Bufo periglenes_ went extinct instead of being established in the hands of zoos and hobbyists? How can you answer yes and still call yourself a conservationist and frog lover?



savethefrogs said:


> Finally, remember the math:
> 100 million amphibians being shipped around the world each year. Some captive populations have 60% prevalence of chytrid. What are the chances that no sick amphibian or the water in which a sick amphibian was held will escape into the environment in the next 100 years at current trade volumes and with no mandatory disease testing? I think less than 0.00000001% chance.


A study on bullfrogs in the food industry is relevant to the hobby in what way? They make terrible captives, not too many hobbyists keeping them.



savethefrogs said:


> Batrachochytrium dendrobatidis was first isolated from a captive dendrobatid. Let's make sure captive frogs don't spread disease to wild populations.


That may be so, but it was later found in preserved specimens dating back to 1937 if I remember correctly. Chytrid was here long before private Dendrobatid keepers.


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## Azurel

Reefers have been fighting the same type of regulation and proposals in the reefing hobby for 10+ years. It always comes down to killing off the hobby in one form or another as much as they say that is not the intent. 

Good post Tony.....


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## Web Wheeler

savethefrogs said:


> It will not be possible to save the frogs if people rate their own personal needs over those of the frogs. There are simply too many humans, and too many threats to frogs.


From this statement alone, your position with regards to the USF&WS proposal seems untenable because, as you have noted, there are too many humans and too many threats to frogs. Why, therefore, would you support regulations that quite likely will negatively affect captive breeding efforts? Is it your position that frog extinctions, in the wild, are preferable to preservation in captivity?


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## Vermfly

Now that I've seen your post Kerry I'm glad I did not support your organization at the Sacramento Reptile Show. I'm actually pretty disgusted because I agree with others on this board that your presense at the show is deceptive because you don't talk about the fact that you support the complete destruction of our hobby. I do support some of your initiatives like the frog pond project but I will never support you with a donation.

Cliff

Sent from my MB300 using Tapatalk


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## donstr

Vermfly said:


> Now that I've seen your post Kerry I'm glad I did not support your organization at the Sacramento Reptile Show. I'm actually pretty disgusted because I agree with others on this board that your presense at the show is deceptive because you don't talk about the fact that you support the complete destruction of our hobby. I do support some of your initiatives like the frog pond project but I will never support you with a donation.
> 
> Cliff
> 
> Sent from my MB300 using Tapatalk


HAHAHA! Man, you guys are a riot! This man is actually doing something to try to help save frogs and you're all crying about your aquarium pets. It really blows my mind. 

Yeah, so maybe you have different opinions about they way to go about saving frogs, but every time Kerry has come on this board he's gotten crap. Here is a man that might love frogs more than each of you and shows it in what he does. When's the last time any of you did anything to actually help amphibians other than stuffing one in a tank?

Yeah, I keep frogs in tanks, too. I like them, too. I'm just saying...


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## Vermfly

I think his goal is admirable but completely destroying dart frog hobby isn't going to stop Chytrid so why should I support an organization whose goal is counter to my interests and I feel, to the ultimate survival of some of these species. Maintaining the captive bloodlines should be the goal of any real conservation group.

Cliff

Sent from my MB300 using Tapatalk


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## Azurel

donstr said:


> HAHAHA! Man, you guys are a riot! This man is actually doing something to try to help save frogs and you're all crying about your aquarium pets. It really blows my mind.
> 
> Yeah, so maybe you have different opinions about they way to go about saving frogs, but every time Kerry has come on this board he's gotten crap. Here is a man that might love frogs more than each of you and shows it in what he does. When's the last time any of you did anything to actually help amphibians other than stuffing one in a tank?
> 
> Yeah, I keep frogs in tanks, too. I like them, too. I'm just saying...


Can you have both happen or just one? That is the question.

These people are doing the same thing in more then just Darts.....Their viewpoint is you can't have the hobby and save the frogs or corals or what ever it is they are looking to save without destroying the hobby at the same time even though some of the biggest leaps in care, research, knowledge come from the hobby side due to privet citizens having the ability to keep said animals. But that part don't matter to them because their agenda is far more important then what some scumbag hobbyist thinks or wants. Instead of coming from the "let's work together" approach they would rather see what we love and want disappear and surrender to their agenda.

Do I agree with some of it? Yes I do, from what I have researched about darts and amphibians, but having my former hobby under assault by the same agenda of which I spent 25 years in some of the biggest leaps in knowledge in keeping corals like SPS and fish breeding didn't come from a lab or scientist with a grant, or these people with an agenda, but from hobbyist that were willing to put time in and invest large sums of money to experiment on their own. 

To them is an all or nothing trade off, with you, us, me with the nothing portion while they can go back to their friends and paymasters and pat themselves on the back saying they did a great job. In the end nobody will win them, us the frogs. 

Why? Because of narrow minded ideologies that are pushing these types of regulations and proposals. Those in the Elite Washington legislators and lobbyist that can make this stuff law don't care about you or the frogs hell 99% of them probably don't even know these animals exist, but if they can put a feather in their cap well then that is all that matters. Because at some point they can use it toget votes or cash.....


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## Web Wheeler

donstr said:


> HAHAHA! Man, you guys are a riot! This man is actually doing something to try to help save frogs and you're all crying about your aquarium pets. It really blows my mind.
> 
> Yeah, so maybe you have different opinions about they way to go about saving frogs, but every time Kerry has come on this board he's gotten crap. Here is a man that might love frogs more than each of you and shows it in what he does.


FYI, while Dr. Kerry Kriger is doing some things to "save the frogs", he isn't the only person doing so, and I have no doubt he's making a LOT of money from donations coming from his website. Just about every page has a "Donate" link. Furthermore, because of his position against the pet trade, I would put him in the same category as PETA, HSUS, et. al.



donstr said:


> When's the last time any of you did anything to actually help amphibians other than stuffing one in a tank?


You seem to have no idea what role DB plays in the captive breeding of Dart Frogs or how much knowledge has been acquired and shared freely by dedicated frog hobbyists on this site.


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## savethefrogs

It is somewhat disheartening to hear you all talking about the extinction of wild amphibians as being inevitable. With an attitude like that then yes you should sit at home and breed your amphibians without regard for anything happening outside your home. Alternatively, you can take action and save species from disappearing from the homes they have inhabited for millions of years. Amphibians will NOT inevitably go extinct if everybody works to save them. 

With regards to those saying that SAVE THE FROGS! supports the destruction of your trade, I cannot recall ever saying that, nor does our website mention that. If it does, please post the URL. Nor have we ever campaigned to that end. The paper you cite for which I am the lead author was written under the stated affiliation of "Centre for Innovative Conservation Strategies, School of Environment, Griffith University, Gold Coast, Australia", so you need not extrapolate those views to the views of SAVE THE FROGS!, which has a 7 person Board of Directors, a 30+ person Advisory Committee and many members in and out of the pet frog world.

In my first post in this thread, I offered a way to help your industry, while at the same time helping wild amphibians. I also provided a link to free chytrid detection protocols that I created in my unpaid time. Before you bash me, please state what you have done in your free time to help your industry and wild amphibians.

To the person who said that I should not have been at the Sacramento Reptile Show, I am wondering if you saw the presentation I gave (and if not why not?), or if you came to our table to see what we were doing (we were educating people about frog extinctions) or talk to me. In the 8 hours I was there, nobody asked me my views on amphibians as pets, and I never brought up the issue. Had someone engaged me in a discussion I would have been happy to speak about it. Based on the reception we received, it seemed quite apparent that the vast majority of people with whom we had contact were quite happy that we were there.

It is the responsibility of the pet trade to ensure that their activities are not spreading pathogens, and the oft-repeated statement that I see on this forum -- that chytrid is already here so it doesn't matter what we do -- is naive and incorrect. Chytrid is not yet everywhere. Even where it exists, we need to protect those amphibians from new strains AND from other diseases, of which chytridiomycosis is but one of many. 

Kerry Kriger, Ph.D.
SAVE THE FROGS! Founder, Executive Director & Ecologist


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## savethefrogs

Web Wheeler said:


> FYI, while Dr. Kerry Kriger is doing some things to "save the frogs", he isn't the only person doing so, and I have no doubt he's making a LOT of money from donations coming from his website. Just about every page has a "Donate" link. Furthermore, because of his position against the pet trade, I would put him in the same category as PETA, HSUS, et. al.
> 
> You seem to have no idea what role DB plays in the captive breeding of Dart Frogs or how much knowledge has been acquired and shared freely by dedicated frog hobbyists on this site.


Web Wheeler,
First, I do know that this forum shares your knowledge freely and that is good. I certainly hope you all are in contact with those involved in captive breeding for re-release into the wild.

As for your statements regarding my income and how much money SAVE THE FROGS! brings in, it is quite clear you have not seen our publicly available IRS FORM990 downloadable at http://savethefrogs.com/who-we-are/ , which shows SAVE THE FROGS! total 2009 revenues as being $57,709 and my total 2009 salary including benefits being $9,555.
Our 2008 revenues were roughly $7,000 and my salary plus benefits was $0. Our publicly available bylaws, also on the aforementioned webpage, show that my salary is capped at $40,000 (though I have never even approached this income). It should also be clear that I work far more than 40 hours per week for SAVE THE FROGS! 

I have degrees in Mechanical Engineering and Environmental Science, as well as many technological, teaching and musical skills that I could be using to earn significantly far more money than I do by saving frogs from extinction; I put my time into SAVE THE FROGS! -- at significant financial sacrifice -- because it is the right thing to do. Money is not my concern, saving frogs is. 

In summary then, your statements about my and STF's financial interests and status are thoroughly incorrect and misleading.
Kerry


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## Tony

So give a straight answer to a simple question: Do you support the right of private citizens to maintain amphibian collections? A yes or no will do.


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## Web Wheeler

savethefrogs said:


> As for your statements regarding my income and how much money SAVE THE FROGS! brings in, it is quite clear you have not seen our publicly available IRS FORM990 downloadable at http://savethefrogs.com/who-we-are/ , which shows SAVE THE FROGS! total 2009 revenues as being $57,709 and my total 2009 salary including benefits being $9,555.


You're quite correct that I've not seen the "SAVE THE FROGS" IRS FORM990, as the last time I visited your site this information was not available. A quick check on the date of your PDF shows it was created on July 28, 2010, and I have not visited your site since then. However, judging by your travels, which include...



> Travel
> 
> I am a nomad. I slept in my tent for forty straight nights in New Zealand. I captained a boat up the Orinoco Delta in Venezuela. I came face to face with a bushmaster a day’s walk from civilization on the north coast of Trinidad. I climbed a mountain in the Himalayas. I looked south towards Antarctica from the southernmost tip of South America. I stuck my hand in the Arctic Ocean. I lived on a glacier in Alaska for a month. I panned for gold in French Guiana. I ran down a mountain in a hailstorm in the Black Hills of South Dakota. I kayaked a tributary of the Amazon that was so wide I couldn’t see the far shore. I slept under the Milky Way in the Utah desert. I played bamboo flute on the banks of the Ganges. I played drums in the Grand Bazaar in Istanbul. I went scuba diving on the Great Barrier Reef. I had an island in Fiji to myself one night. I walked four days to the border of Guyana. I watched the sun set over the Guatemalan rainforest from the top of a 1,200 year old Mayan ruin. I walked hours off trail into the Australian rainforest in the middle of the night and found my way back by following a string I had laid on the way in. I had a snowball fight on top of Hawaii’s highest mountain on the summer solstice. I navigated out of the Kau Desert in the middle of the night using the North Star to guide me. I got malaria in Papua New Guinea. I woke at dawn every other day for a month to feed baby peregrine falcons above a cliff 700 feet above the ocean in California. I bushwacked through devil’s club in the North Cascades. I learned Spanish slang in the cab of an 18-wheeler rolling through the Patagonian night. I hitchhiked in Colombia. I rode in a hot air balloon over the Serengeti at sunrise. I watched an opera in a park in Rome. I hiked to a frozen waterfall in Croatia. I skied the Olympic ski slopes above Sarajevo. I climbed 4,000 ft to see a endangered bird on top of Mt. Gower, and then I descended and snorkeled the world’s most southerly coral reef. I walked into a Panamanian swamp in the middle of the night to photograph red-webbed gladiator frogs. I got lost in a whiteout in the Andes and survived the night by starting a cow-dung fire to stay warm. I broke camp in two minutes when I saw hundreds of thousands of ants coming towards my tent in Brazil. I learned the Tibetan alphabet and held a conversation in Mandarin. I rappelled into a crevasse. I caught a piranha and ate it. I tracked howler monkeys through the rainforest in Mexico. I stared into a crater of boiling lava atop a volcano in Chile. I soaked in a hot spring underneath Bolivia’s highest mountain. I watched a condor soar above Colca Canyon in Peru. I got healed by a shaman in Thailand. I canoed past bull sharks in Costa Rica.
> 
> Source: Travel Photos


...I assumed the money to support such expeditions came from "SAVE THE FROGS". My mistake, and I apologize for my incorrect assumption.


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## Azurel

> With regards to those saying that SAVE THE FROGS! supports the destruction of your trade, I cannot recall ever saying that, nor does our website mention that. If it does, please post the URL. Nor have we ever campaigned to that end.


You don't have to come out and say it....The support for legislation that comes from this type of proposal is enough.

I think we can all agree that we don't want the spread of Chytrid wither it's in the hobby or in the wild. I think we can all agree that testing and having amphibians being certified would be a good thing. The problem arises when these types of proposals get changed down the road, or in legislation once out of the public eye and in the dark of night.

If the only thing that happens is any amphibian or dart frog gets tested for Chytrid and those with positive test go to research facilities, zoos, conservation facilities and those that don't can then be placed into the privet sector for sale, I think that everyone would be fine if there was a gaurentee that that is the only thing that would happen even if me as a privet citizen has to have my frog's offspring tested before sale I would be fine with that because that only reinforces the safety of the frogs I have. But we all know that is not the end goal of these things and never is.....EVER and never has been in the past.

So post like these come from the mis-trust of those that propose these types of proposals, mistrust from those that legislate them because time and time again they have shown to have a far more reaching and destructive agenda aimed at the real target which is privet ownership of live exotic animals....

In the end also this only creates and deepens the black-market trade of which we are all against because that does harm to everyone and most importantly the frogs and amphibians.


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## billschwinn

The previous posts info on the world wide walkabout, if it is funded by donations for saving frogs, if this is true, would be repugnant behaviour in my opinion. I would like some clarification on this.


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## Chris Miller

Tony said:


> So give a straight answer to a simple question: Do you support the right of private citizens to maintain amphibian collections? A yes or no will do.


Yes. Please answer the question, it seems like you may not be getting a fair shake, but avoiding the question looks bad.


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## Web Wheeler

Dr. Kriger,

Considering the damage your paper, Chytridiomycosis, Amphibian Extinctions, and Lessons for the Prevention of Future Panzootics, has likely inflicted upon the pet industry, and by extension, pet hobbyists in general, with statements such as this:



> Preventing disease spread into naive amphibian populations can only be accomplished by removing the source of the problem: the translocation of infected amphibians. Unlike zoos and laboratories, whose conservation services render the translocation of amphibians an occasional necessity, the amphibian pet and bait trades are for the large part disposable, that is, they are unnecessary, serving little benefit to society. Their nearly complete dismantling would benefit amphibian populations, not only by eliminating a primary source of disease transfer, but also by simultaneously reducing the over-harvesting of wild amphibian populations, which is largely unregulated in many parts of the world (Li and Wilcove, 2005; Schlaepfer et al., 2005). At a minimum, these trades should be restricted to local sales of captive-bred individuals.


I think everyone here, and indeed all private amphibian keepers, deserve nothing less from you than a complete repudiation of those remarks and a clear, unambiguous statement from you acknowledging the accomplishments and endorsing the freedom of private individuals to keep and breed amphibians.

Speaking for myself, if you can provide such a statement, then you will see a marked difference in your reception, on this forum, from me.


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## johnc

I have talked to many people about this in the past - I do not understand the purpose of having a second organization when we already have Amphibian Ark (and *had*, before Save the Frogs). Case in point, Amphibian Ark approached Caudata.org (basically a dendroboard for newt and salamander enthusiasts) a few years ago to raise money from hobbyists to fund a wild amphibian conservation grant. We're now entering our 3rd year of running this grant. That's an example of a professional organization that will work with hobbyists. When it comes to Save the Frogs, I am skeptical of an organization whose "founder" pushes his own name and credentials as much as the organization itself.

John P. Clare, Ph.D. (hey, when in Rome, right?)


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## Web Wheeler

savethefrogs said:


> With regards to those saying that SAVE THE FROGS! supports the destruction of your trade, I cannot recall ever saying that, nor does our website mention that. If it does, please post the URL. Nor have we ever campaigned to that end.


Perhaps you forgot about your little speech to the California Department of Fish & Game on April 8, 2010 advocating for a ban on the importation of all non-native frogs and turtles?



> Though assertions have been put forth that this ban improperly targets Asian communities due to the lack of a concurrent regulation of non-native frogs and turtles for use as pets, two wrongs do not make a right: a lack of proper regulation of the pet industry does not justify a failure to act intelligently with the food industry. Indeed *I also urge the Department of Fish & Game to consider similar regulations on the import of non-native frogs and turtles for use as pets.*
> 
> Emphasis in *bold* is mine (W.W.).
> 
> Source: http://www.savethefrogs.com/frogblo...ortation-of-non-native-frogs-for-use-as-food/


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## savethefrogs

billschwinn said:


> The previous posts info on the world wide walkabout, if it is funded by donations for saving frogs, if this is true, would be repugnant behaviour in my opinion. I would like some clarification on this.


Bill,
Thank you for the compliment. By implying that I could build the world's leading amphibian conservation and education organization from scratch, with minimal funding, in only 2.5 years, while at the same time traveling to more places than most people will ever set foot demonstrates that you view me as being larger than life. However, it would be unrealistic to envision it as being even remotely possible, and indeed your description of my travels as being funded by SAVE THE FROGS! are thoroughly incorrect.
Kerry


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## savethefrogs

Web Wheeler said:


> Perhaps you forgot about your little speech to the California Department of Fish & Game on April 8, 2010 advocating for a ban on the importation of all non-native frogs and turtles?


I don't recall ever being asked about that here, and no I have not forgotten about my speech. Indeed, you can listen to it on SAVE THE FROGS! Audio Page along with a wealth of other freely downloadable recordings about frog conservation I have made.

I believe the opposition that day had a few lines of reasoning for why the importation of non-native frogs and turtles for use as food (that was the order of the day) should not be banned:
1- frogs and turtles are very tasty
2- frogs and turtles are good for one's health
3- frogs and turtles have been my people's food for 5,000 years
4- frogs and turtles are fun to have as pets
I do not recall anybody standing up and saying that imported frogs and turtles do not spread disease to native populations. 

Thank you for bringing up this campaign, for which SAVE THE FROGS! supporters submitted 1,275 letters in favor of the ban. This comprised over half the letters received by the CA Fish & Game Commission, and I felt proud to be part of the legislative process and to help put an end to the absurd importation of non-native frogs and turtles for use as food. 

Another few million frogs saved.
Kerry


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## savethefrogs

Web Wheeler,
Nor did anybody stand up that day and state that imported frogs and turtles do not become harmful invasive species. Seeing the damage that American Bullfrogs have done to amphibian populations in the American West and around the world, it is quite obvious why nobody would have stated such a thing.
Kerry


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## savethefrogs

johnc said:


> I have talked to many people about this in the past - I do not understand the purpose of having a second organization when we already have Amphibian Ark (and *had*, before Save the Frogs). Case in point, Amphibian Ark approached Caudata.org (basically a dendroboard for newt and salamander enthusiasts) a few years ago to raise money from hobbyists to fund a wild amphibian conservation grant. We're now entering our 3rd year of running this grant. That's an example of a professional organization that will work with hobbyists. When it comes to Save the Frogs, I am skeptical of an organization whose "founder" pushes his own name and credentials as much as the organization itself.
> 
> John P. Clare, Ph.D. (hey, when in Rome, right?)


John,
The work of SAVE THE FROGS! and the Amphibian Ark have virtually no overlap. If you think we do the same thing, then you have likely not spent more than a few minutes on our website. 

Furthermore, it is clear you do not receive our electronic newsletter, which you should. Actually everybody who is reading this should subscribe right now at SAVE THE FROGS! - Newsletter

Regardless of your opinion of SAVE THE FROGS! it sure seems like you'd want to know what we are up to. 
Kerry


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## savethefrogs

Web Wheeler said:


> Dr. Kriger,
> 
> Considering the damage your paper, Chytridiomycosis, Amphibian Extinctions, and Lessons for the Prevention of Future Panzootics, has likely inflicted upon the pet industry, and by extension, pet hobbyists in general, with statements such as this:
> 
> I think everyone here, and indeed all private amphibian keepers, deserve nothing less from you than a complete repudiation of those remarks and a clear, unambiguous statement from you acknowledging the accomplishments and endorsing the freedom of private individuals to keep and breed amphibians.
> 
> Speaking for myself, if you can provide such a statement, then you will see a marked difference in your reception, on this forum, from me.


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


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## savethefrogs

johnc said:


> I have talked to many people about this in the past - I do not understand the purpose of having a second organization when we already have Amphibian Ark (and *had*, before Save the Frogs). Case in point, Amphibian Ark approached Caudata.org (basically a dendroboard for newt and salamander enthusiasts) a few years ago to raise money from hobbyists to fund a wild amphibian conservation grant. We're now entering our 3rd year of running this grant. That's an example of a professional organization that will work with hobbyists. When it comes to Save the Frogs, I am skeptical of an organization whose "founder" pushes his own name and credentials as much as the organization itself.
> 
> John P. Clare, Ph.D. (hey, when in Rome, right?)


John,
Another obvious reason to have multiple amphibian conservation organizations is that amphibians are involved in the largest extinction event in 65 million years. 

I am sure you would agree that it is good to have more than one organization devoted to any of the following:
-global warming
-reducing teen pregnancy
-reducing violent crime, high school dropouts, heroin use, etc...
Kerry


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## johnc

Hi Kerry.

I've known of Save the Frogs for several years. At some point I read your web site top to bottom. From an amphibian point of view, I still fail to see why you found it necessary to create your own organization rather than collaborating with Amphibian Ark. All of your enthusiasm could really bolster them. I am at a loss as to why you continually drop your own name and credentials though - shouldn't this be about your organization's agenda and accomplishments, not you as an individual?

Anyhow:



savethefrogs said:


> Regarding the pet trade, my main concerns are disease spread, and taking amphibians from the wild.
> The former has received ample discussion here already.


Yes, discussed here largely by the uninformed, as well as members of TWI who wish to be seen as a legitimate conservation body (sorry, I'm a member of TWI but I am under no illusions as to its realistic relevance to conservation - no offense Ron and everyone). I find it saddening that those who really could form an intelligent and informed debate against this proposed legislation are better at holding their tongues than I.



savethefrogs said:


> (1) It is thoroughly unethical to take an amphibian from its home in the wild and sever its ability to return to its home;


I can't help but read an almost PETA-like logic into this statement. And your statement dismisses the work of Understory Enterprises who sustainably breed dart frogs, as well as manage and conserve their habitat. Money from Understory sales goes straight back into their conservation work. The world is not black and white, Kerry.



savethefrogs said:


> (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.


USFWS are not known for their love of hobbyists. If this becomes legislation, it will make life perhaps more difficult for hobbyists with captive bred offspring than for importers/exporters. There is no way (even based on finance alone) that we will be able to go to the local vet for a chytrid test and anyone who believes otherwise needs to take the rose-tinted glasses off.



savethefrogs said:


> 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.


You're a well published scientist in peer-reviewed journals. You know that sweeping generalizations are a big no-no there, so why impose them on the lay man. It's disingenuous and frankly smacks of PETA "speak". I would never have become a scientist but for collecting frog spawn as a young child. I feel that commercial exploitation of amphibian species that takes place without a mind to conservation, or some legal oversight is morally objectionable, but lawmakers have a tendency to ban first and ask, well, they don't ask questions later. That is 50% of the reason for my objection to the current proposal. 

The other 50% is the fact that we, the hobbyist, will fall victim to these regulations when we are the least likely contributors to the problem. Outlaw fishing with salamander larvae and tadpoles. Ban interstate transport of native larval amphibians. The sad fact is that much (perhaps most?) of the spread of chytrid in the US is due to species like the American Bullfrog that can carry the pathogen but not suffer to any significant degree. It's a documented fact that scientific researchers themselves have been to blame for the extinction of some California frog populations because they spread the disease themselves. By all means regulate all of the above, and at the same time ban farming of bullfrogs for the food industry. Sadly, most of the damage that can and will be done is in motion right now because of these factors. Imposing new regulations will serve as little more than lip service to lobby groups that jump from issue to issue as self-promotion and to garner publicity for donations. Defenders of Wildlife are a prime example. I'm sure PETA will be all over this in the coming months too. These regulations, to do any good, should have been brought in shortly after the description of chytrid. 



savethefrogs said:


> John,
> Another obvious reason to have multiple amphibian conservation organizations is that amphibians are involved in the largest extinction event in 65 million years.


That may well be so, but it's not because we are keeping dartfrogs and other amphibians, and it shouldn't be us who suffer because of ill-informed law making. I've mentioned the main culprits in this problem already, but how about the US state department gets involved by lobbying countries like Panama (which is practically a US protectorate) to stop habitat destruction in the rainforest and ban home construction in exotic locales. How about lobbying other governments to actually enforce their own laws against smuggling of amphibians by individuals and by fish exporters/importers. There's a long list of more useful approaches to this problem than what USFWS is currently considering.



savethefrogs said:


> I am sure you would agree that it is good to have more than one organization devoted to any of the following:
> -global warming
> -reducing teen pregnancy
> -reducing violent crime, high school dropouts, heroin use, etc...


Does "Save the Frogs" really describe your organization then?

Not to go off topic too much, but if you're after the heroin, struth, what about the cannabis, Kerry? 

-John

(Please be gentle, moderators)


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## billschwinn

Kerry, you should really read , yes read my previous post, I was not describing anything about you or your group, it was a question about a previous post from someone else, I was looking for clarification to what was presented, i.e. you to give your side to something that I saw as troubling. I do have to let you know that I have never heard of you before this thread, so therefore I had nothing to base an opinion of you on.I would say that after reading your interactions here with me and others, I feel as though you appear to be arrogant and seem to talk down to people.That is not a trait I find admirable in people. This situation with The FWS /Chytrid response period will not be aggreed on by both sides, but unless people can talk as equals and work through compromise, and not be pretentious or not take into account the others views, the only losers will be the frogs.If we really care about the frogs, both sides will have to feel they have had their concerns Really taken into consideration, In the end Phd's and attitudes and hidden agendas have to be put aside, they really don't matter, if we as people really care about the frogs.


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## Web Wheeler

Dr. Kriger,

You've completely avoided the tough questions and instead offered up your simplistic "SAVE THE FROGS!" propaganda as if we are all naive children, which, in my opinion, also characterizes your response to Garner, et. al., The Amphibian Trade: Bans or Best Practice?.


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## Tony

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?


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## savethefrogs

John,
Your listing of the multitude of amphibian threats and its use to justify focusing on issues other than disease spread by the pet trade is akin to Syngenta's website listing chytrid as a threat to frogs and using that to imply that pesticides are not a problem. Amphibians are rapidly disappearing due to a multitude of threats, all of which need to be dealt with. Chytrid is a primary threat to amphibian biodiversity.

As for the Amphibian Ark, on multiple occasions I have asked them if they would like to partner for Save The Frogs Day (the world's largest day of amphibian education and conservation action) but I do not receive responses. The letters they sent me in the early days of Save The Frogs were to get me to dissolve the organization and they have not contacted me since. Perhaps you should be asking them why they do not work with Save The Frogs. 

As for your statement that there was never a need to start Save The Frogs, the end justifies the means, and many times over Save The Frogs has proven its worth. You may be very interested in my radio interview on Martha Stewart Radio on Save The Frogs Day for an interesting discussion on the origins of Save The Frogs. 

Finally, my analogy to organizations working with crime, etc was to demonstrate that all large problems have multiple organizations, luckily.

Bill who accuses me of having attitudes and hidden agendas: step into the snake pit and try to defend yourself amidst people who consistently defame you and see how long you remain congenial. As for hidden agendas, what is hidden? I answer all your questions and my life is open for all in my published papers and websites.

Web Wheeler, I haven't avoided any questions related to this thread, which is about controlling chytrid fungus. If you were looking for yes/no answers on other topics I haven't addressed, you should realize that I usually write multiple page papers about any issue, or long web pages, because there are few issues that can be adequately explained in a two or three letter word. When SAVE THE FROGS! issues position statements that may be of interest to those on this forum, I will be sure to post links to them here.

Until then,
Kerry Kriger, Ph.D.
SAVE THE FROGS! Founder, Executive Director & Ecologist

P.S. John, I sign my name with a link to my page not because of arrogance or self-promotion but because my first post ever on this site was left unsigned and many Dendroboarders gave me a thorough bashing because of it. 
P.P.S. If anyone wants to know the true story of SAVE THE FROGS!, the answer lies within.


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## Chris Miller

So give a straight answer to a simple question: Do you support the right of private citizens to maintain amphibian collections? A yes or no will do.

I'm honestly curious. Everyone has the right to have their own opinion, however it's disingenuous to hide it for your own gain. You are a scientist after all, not a politician.


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## johnc

I'm finished trying to have a conversation Kerry - you miss the points, then deflect any question, rather than discuss them. Best of luck to you and your organization - I am sure you will continue to go from strength to strength. Truly, I hope that is a good thing.


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## Web Wheeler

> They defended the frogs’ legal rights when the government failed to do so, and they fought to create necessary laws when none existed.
> 
> Source: The Story of SAVE THE FROGS!


I wonder, where have I heard about legal rights for animals?


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## savethefrogs

Tony said:


> 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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## Tony

savethefrogs said:


> 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?



savethefrogs said:


> 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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## johnc

All this thread has served to do now is increase savethefrog's google page ranking due to all the link posting.


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## Tony

johnc said:


> All this thread has served to do now is increase savethefrog's google page ranking due to all the link posting.


I suspected that was his intent and took the time to remove the links any time I quoted him.


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## Web Wheeler

I think the last few pages of posts have uncovered some things about SAVE THE FROGS! and Dr. Kriger that he would rather not discuss, at least not here anyway.


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## Chris Miller

savethefrogs said:


> 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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## Chris Miller

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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## zBrinks

savethefrogs said:


> 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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## Web Wheeler

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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## SethDoty

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.


----------



## Web Wheeler

SethDoty said:


> 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.


----------



## Dane

savethefrogs said:


> 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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## earthfrog

savethefrogs said:


> 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,


----------



## Rain_Frog

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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## Ed

Rain_Frog said:


> 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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## Roadrunner

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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## johnc

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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## johnc

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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## billschwinn

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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## Ed

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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## AaronAcker

JohnC that was great. Thank you all who wrote in, I hope we hear final word on this soon.


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## Web Wheeler

My comments are here.


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## johnc

billschwinn said:


> 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.


Bill, I understand what you're saying. Sadly, the number of people commenting from hobbyist sites is incredibly small. Really, when it comes down to it, 488 comments up until close of business today (obviously that doesn't count the ones made after the clerical workers at USFWS went home for the day) is a small amount when compared to the membership of hobbyist amphibian sites. Looking at the names, I recognized 10-20, and only a few from dendroboard. 

I hope there were other last minute people like myself (I always leave everything to right before deadlines!). But if there aren't, don't take it personally - that's just the way people tick.



Ed said:


> 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, I sincerely doubt USFWS' mailbox was full.



Web Wheeler said:


> My comments are here.


Wow Web, that was fantastic. You obviously put a lot of work into it. Well done.


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## Web Wheeler

johnc said:


> Wow Web, that was fantastic. You obviously put a lot of work into it. Well done.


Thank you, John! Coming from you, this means a lot to me. I would have liked to organize my citations and connect the dots a bit more, and I noticed there are a number of typos that should be corrected, but, like you, I tend to leave things to the last minute.

For anyone who's interested, here's a link to most of the research papers I cited in my reply to the DOW petition:

Articles on Batrachochytrium dendrobatidis: the amphibian chytrid


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## AaronAcker

Great job Web. I even saved both your and johns letters... A lot of good info in both. I hope we hear about this soon.


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## johnc

I am a little perturbed that my comment hasn't shown up on their site today, yet it was submitted yesterday...

However I don't see a submit comment option any more.


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## billschwinn

Can someone post a link to the comments as I don't see that option any more.


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## Web Wheeler

billschwinn said:


> Can someone post a link to the comments as I don't see that option any more.


Go here and check the box that says "Public Submissions."


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## Baltimore Bryan

johnc said:


> I am a little perturbed that my comment hasn't shown up on their site today, yet it was submitted yesterday...
> 
> However I don't see a submit comment option any more.


I was also a little surprised that my comment did not show up yet, but there were other comments also submitted the same day I sent mine... I touched on many of the same points you did, but worded it slightly different and also talked about some other things. I hope there were more comments submitted from hobbyists than only what is showing up right now.
Bryan


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## JJuchems

I submitted mine at the last minute (Not posted yet). I used part of TWI response along with some if the citations I posted. One of the biggest things is to keep your comments short and to the point. Multi page responses will not get read. If you submitted a long response, I mean no disrespect, but it is the sad. Mine ended up two pages with citations, with the response on page one. Here is what I summited:



> U.S. Fish and Wildlife Service
> Division of Policy and Directives Management
> Attn: Docket No. FWS-R9-FHC-2009-0093
> 4401 N. Fairfax Drive, Suite 222
> Arlington, VA 22203
> RE: Docket No. FWS-R9-FHC-2009-0093
> 
> Dear Fish & Wildlife Service,
> I am concerned with the current request to stop all transportation of amphibians under the Lacey Act. Batrachochytrium dendrobatidis is a threat to all amphibians and has shown a decline in populations globally (1-4). There is evidence that imported amphibians for the food industry may be harboring Bd (5-8). Research has also been shown this deadly fungus can be carried by migratory birds (9), which would transport this fungus to millions of locations. In addition, fish could also carry Bd and fisheries pools can contaminate our water resources (10).
> Restricting the movement of amphibians will do little if nothing to stop the spread of amphibian Bd. It is worth noting that some wild populations have rebounded with some species such as chorus frogs and bull frogs becoming resistant. With little know on how the rapid spread the addition of all amphibians to the Lacey Act will not stop the spread of Bd. No evidence has been shown that Bd has spread through the pet trade, or that it may have spread through the transportation of amphibians in the private sector.
> 
> Jason Juchems
> 2005 and 2008 President of the Central Illinois Herpetological Society
> 
> 1) Berger L, Speare R, Daszak P, Green DE, Cunningham AA, Goggin CL, Slocombe R, Ragan MA, Hyatt AD, McDonald KR, Hines HB, Lips KR, Marantelli G, Parkes H. Chytridiomycosis causes amphibian mortality associated with population declines in the rain forests of Australia and Central America. Proceedings of the National Academy of Science, USA 1998;95: 9031-9036.
> 
> 2) Berger L, Speare R, Hyatt A. Chytrid fungi and amphibian declines: Overview, implications and future directions. Declines and Disappearances of Australian Frogs. Ed. A. Campbell. Environment Australia: Canberra. 1999:23-33.
> 
> 3) La Marca E, Lips KR, Lotters S, Puschendorf R, Ibanez R, Rueda-Almonacid JV, Schulte R, Marty C, Castro F, Manzanilla-Puppo J, Garcia-Perez JE, Bolanos F, Chaves G, Pounds JA, Toral E, Young BE. Catastrophic population declines and extinctions in neotropical harlequin frogs (Bufonidae : Atelopus). Biotropica 2005;37(2):190-201
> 
> 4) Lips KR, Burrowes PA, Mendelson JR, Parra-Olea G. Amphibian population declines in Latin America: Widespread population declines, extinctions, and concepts. Biotropica 2005;37(2):163-165
> 
> 5) Fisher MC, Garner TWJ. The relationship between the emergence of Batrachochytrium dendrobatidis, the international trade in amphibians and introduced amphibian species. Fungal Biology Reviews 2007;21:2-9.
> 6) Mazzoni R, Cunningham AC, Daszak P, Apolo A, Perdomo E, Speranza G. Emerging pathogen of wild amphibians in frogs (Rana catesbiana) farmed for international trade. Emerging Infectious Diseases 2003;9(8):995-998.
> 
> 7) Garner TWJ, Perkins MW, Govindarajulu P, Seglie D, Walker S, Cunningham AA, Fisher MC. The emerging pathogen Batrachochytrium dendrobatidis globally infects introduced populations of the North American bullfrog, Rana catesbeiana. Biology Letters 2006: doi:10.1098/rsbl.2006.0494.
> 
> 8) Hanselmann, Rhea; Rodríguez, Argelia; Lampo, Margarita; Fajardo-Ramos, Laurie; Aguirre, A. Alonso; Kilpatrick, A. Marm; Rodríguez, Jon Paul; Daszak, Peter; Magnitude of the US trade in amphibians and presence of Batrachochytrium dendrobatidis and ranavirus infection in imported North American bullfrogs (Rana catesbeiana), Biological Conservation, Volume 142, Issue 7, July 2009, Pages 1420-1426
> 
> 9)	Johnson, Megan L.; Speare, Richard; Possible modes of dissemination of the amphibian chytrid Batrachochytrium dendrobatidis in the environment. Disease of Aquatic Organisms. Vol. 65. 181-186. 2005
> 
> 10)	Green, D. Earl; Dodd, C. Kenneth Jr; PRESENCE OF AMPHIBIAN CHYTRID FUNGUS BATRACHOCHYTRIUM DENDROBATIDIS AND OTHER AMPHIBIAN PATHOGENS AT WARMWATER FISH HATCHERIES IN SOUTHEASTERN NORTH AMERICA. Herpetological Conservation and Biology 2(1): 43-47 Submitted: 7 March 2007, Accepted: 30 March 2007
> 
> 
> Sent notification: 80bb8b79


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## JJuchems

johnc said:


> Bill, I understand what you're saying. Sadly, the number of people commenting from hobbyist sites is incredibly small. Really, when it comes down to it, 488 comments up until close of business today (obviously that doesn't count the ones made after the clerical workers at USFWS went home for the day) is a small amount when compared to the membership of hobbyist amphibian sites. Looking at the names, I recognized 10-20, and only a few from dendroboard.
> 
> I hope there were other last minute people like myself (I always leave everything to right before deadlines!). But if there aren't, don't take it personally - that's just the way people tick.
> 
> 
> Ed, I sincerely doubt USFWS' mailbox was full.
> 
> 
> Wow Web, that was fantastic. You obviously put a lot of work into it. Well done.


This is a very sad turn out of comments. Lets not forget that a portion of these comments are in support of this action. I would say it is plausible that 1/3 of the comments are in support. Putting 300+ comments against. Not a good turnout.


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## Rain_Frog

Amazing how more effort was spent by hobbyists debating the issue on the forum-- where its futile-- than actually spending time writing a letter to the USFWS.

Man, it took me a long time to figure out how to use the submitter search feature but I found my letter.


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## Ed

johnc said:


> Ed, I sincerely doubt USFWS' mailbox was full.
> .


I have no doubts that it was very empty. I mailed my comment in but I kept it short and simple. I mailed it this time as I was wondering if it could be like contacting a politician where mailed comments end up getting greater weight. 

I have a strong suspicion that the ruling is going to go against the petition as the USDA has declared it non-actionable. 

Ed


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## fleshfrombone

Good thing no one's being an alarmist.


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## koolparrot

Any News. It took me 45min to read this article and i am curios to fine the result. 

ANYTHING!!!

Kp


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## koolparrot

Or does anyone know the link or time it will be posted?


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## koolparrot

savethefrogs said:


> Please have a look at savethefrogs.com, the website of SAVE THE FROGS!, a 100% volunteer-based, 501(c)(3) nonprofit organization dedicated to amphibian conservation.
> 
> 
> 
> 
> 
> Thanks!


I thought he said he was paid. Am i wrong???

Kp


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## james67

"he" posted that. (hence the STF screen name)

use the search feature and look to the thread about this organization for further comment though 

james


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## koolparrot

Does anyone know about if this thing passed?


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## JJuchems

It is not a situation of will it pass, such as contacting your legislator. It was open for comments and will probably go to a committee that will make a recommendation. If it goes into effect, it will be done in a similar fashion to the FDA ban on turtles under 4" being offered for sale.


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## moose12

it will be a struggle...we are a mammal-centric society....even in the zoo world....despite frogs being such an indicator species....it will take a lot to pass such important legislation...


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## JJuchems

moose12 said:


> it will be a struggle...we are a mammal-centric society....even in the zoo world....despite frogs being such an indicator species....it will take a lot to pass such important legislation...


This is not a legislation but a rule change. Hug difference, since there is not a congressional vote needed. Rule changes are based on summited comments, hearings, and testimony at hearings.


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## Elliot

Any news on what happened to it?
I look over the article so excuse me if something as already happened to it and I didn't hear about it.


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## JJuchems

Nothing yet...stay tuned.


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## VoidDiver

Snip "I have analyzed over 3,000 chytrid samples and I would guess that a person with a qPCR machine (which is not cheap) could run samples at $5 each."

This is the single biggest deterrence IMO. I will soon be dropping $100+ on my first par of frogs obtained last week to test them. Many people wouldn't be willing or can't do that however. If the sellers don't mention it to newcomers they may not be able to afford the costs of properly keeping a frog. My sellers never mentioned more detail than quarantining new additions.

This is a complicated business issue. Ideally sellers would put ethics and awareness first and enlighten newcomers. This probably won't happen. Also testing would add to the cost so either a seller sells a $50 frog - $30 for testing he only made $20. Alternatively (and not applicable to any possible laws) a responsible buyer does it making it an $80 frog.

If tests could somehow be done for $5 and even more conveniently, by someone onsite at expos that's a cost people of all types and means could handle. I don't think $5 will make or break a buyers decision who to buy from. Furthermore, whether the cost is added to the price or not, saying a frog has been tested chytrid free is a selling point to even a newcomer.


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## bfdshfd

Your position with regards to the USF&WS proposal seems untenable,as you have noted, there are too many humans and too many threats to frogs.


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## pdfCrazy

Who's Position, who are you speaking to? This thread is well over a year old. What "position" do you speak of???


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## bfdshfd

I would personally hate for this hobby (through the importation and/or trade of Bd-infected animals) to be a participant in the further spread of these strains into areas and amphibian populations that have previously been uninfected by them.


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## Dane

bfdshfd said:


> I would personally hate for this hobby (through the importation and/or trade of Bd-infected animals) to be a participant in the further spread of these strains into areas and amphibian populations that have previously been uninfected by them.


Then do your due diligence and regularly test your collection and new acquisitions for harmful pathogens. Be part of the solution.


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## James55

This post is so good and well informative for me.


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