# Attention!!! Effects almost everyone on here



## rcteem (Mar 24, 2009)

*Saw this on another forum and havent seen this much detail posted about this on here. This is very important to everyone on here and can greatly affect our hobby!!!! Thanks John for posting this!!!!

*

This is a reminder that there are only *11* days left to leave a comment on the Federal Register about the proposed ban on the trade/shipping/moving of amphibians over borders between US states by anyone except licensed institutions, etc (that means everyone in the amphibian hobby will no longer be able to ship, bring, or otherwise move their frogs, toads, newts, salamanders, etc, over state borders). 

If you don't do this, it could mean an end to the amphibian keeping hobby. 

Here is my advice for leaving a comment. I encourage you to do your own internet research if you are not familiar with the topic Chytrid fungus (also called B.d.). But here is my advice to you when writing your comment.

Firstly, be polite and civil. Coming across as an angry and unreasonable individual will not help your comment to be taken seriously. When making a comment, back it up with some facts. A comment such as "The ban shouldn't happen because it is a bad idea" does not tell anyone why it is bad and this comment won't be taken seriously by USFWS. So here is what I would do:

Make it clear that you live in the USA, unlike many of the current commentators (who have no right to decide US policy).
You should outline an opinion regarding the proposed legislation with questions like these in mind:
Will it be of any benefit to native amphibians? The "pro-ban" people say yes, but the simple fact of the matter is that chytrid is everywhere in the US right now. A ban like this, at this stage, will give virtually no benefit, if any, to our native amphibians who have already suffered the lion's share of the losses they are likely to suffer, and will cost us a lot of our tax dollars.
Does the pet trade really contribute to the spread of chytrid, at this point in time? Most amphibian experts will tell you that the majority of the disease's spread is due to the bait fishing industry and the amphibians as food industry. Bait fishermen use tiger salamander tadpoles to fish for bass. These tadpoles are often infected with chytrid from other parts of the country and when they are used as bait they introduce chytrid to that water source. The fisherman also have a bad habit of letting their bait go at the end of the day. The frog legs/amphibian as food industry is largely responsible for the spread of the American Bullfrog, which is very tolerant of chytrid, making it a great carrier of the disease. Waste water from these frog rearing facilities can carry chytrid. So when it comes down to it, the pet trade and pet owners don't even figure in the equation when it comes to chytrid spread.
The vast majority of chytrid in the amphibian pet trade comes from the whole salers importing frogs from foreign countries. Instead of making a ban on interstate amphibian trade, shouldn't the USFWS be inspecting and testing amphibian imports when they first reach the US? Why do hobbyists have to be punished instead of big businesses?
When it comes down to it, bearing in mind what I've pointed out earlier, the only real effect that this ban will have is to reduce your freedom as American citizens. This is quite literally another threat to your 4th Amendment rights as citizens of the United States of America.
The ban will likely only effect you as a hobbyist, and the people you know in the hobby, because we are the ones who will have to pay big money to bring or send our frogs over state lines. Companies will just factor it into their prices on frogs and salamanders, etc, passing the cost on to you, and preventing you from ever being able to sell captive bred offspring beyond your local state. Also bear in mind that the ban will cover taking your frogs with you if you move to an out of state home, or you go off to college and want to take your pet with you!
Even if you are not a citizen, if you are paying taxes in the US I think you should voice your opinion. It's a sad fact that most of the comments on the register right now are from foreigners who don't even live in the United States. Let's point that out as much as we can while making reasonable, fact-based arguments against this ban on trade between states of amphibians by ordinary people. 

Please do comment. Your hobby may disappear if you don't.

Deadline
The USFWS will consider information received or postmarked on or before December 16, 2010.

Submit
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.

Additional 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 .

Your comments must be received by December 16th!


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## Dendro Dave (Aug 2, 2005)

rcteem said:


> *Saw this on another forum and havent seen this much detail posted about this on here. This is very important to everyone on here and can greatly affect our hobby!!!! Thanks John for posting this!!!!
> 
> *
> 
> ...


I left a comment. Here is a direct link to the page (If I was commenting on the right thing LOL)...
Regulations.gov

Correct me if I'm wrong but isn't this infection similar to whirling disease in trout? Can't it be passed through the watershed and from boats and fishermen's boots and stuff like that? Seems like banning shipping frogs in our hobby will have minimal impact if any in the real world....just a band aid to placate the panicked masses IMO.


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## johnc (Oct 9, 2009)

Dave, you are right about the other ways it can be spread, unfortunately.


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## Chris155hp (Mar 17, 2010)

This is bs!!!!! (not the post but the government). If i have learned anything about our government is that more then half the time there "facts" are completely incorrect and their "solution" affects the wrong people and does nothing to alleviate the problem. I hope we can stop this!!


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## TDK (Oct 6, 2007)

I've posted my comment. Keep this going.


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## JJuchems (Feb 16, 2004)

rcteem said:


> *Saw this on another forum and havent seen this much detail posted about this on here. This is very important to everyone on here and can greatly affect our hobby!!!! Thanks John for posting this!!!!
> 
> *


 There is a sticky and another thread. Also, no response from USArk. I emailed them with no response, so apparently they do not care for the amphibian hobby.


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## johnc (Oct 9, 2009)

JJuchems said:


> Also, no response from USArk. I emailed them with no response, so apparently they do not care for the amphibian hobby.


Response to what? They have already posted information about the issue and told us how to comment. In fact part of my post was lifted from their information.


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## Dane (Aug 19, 2004)

Dendro Dave said:


> Correct me if I'm wrong but isn't this infection similar to whirling disease in trout? Can't it be passed through the watershed and from boats and fishermen's boots and stuff like that? Seems like banning shipping frogs in our hobby will have minimal impact if any in the real world....just a band aid to placate the panicked masses IMO.


Tires, boots, soil associated with plant shipments, livestock hooves, It can even cross oceans in bilge water on merchant ships. So, yeah, I would say that hobbyists have played a minimal part on the global stage when it comes to Bd, but who has data to back that up?


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## Freeradical53 (Jan 25, 2008)

Is there a test for this disease? Is it difficult to certify that the amphibs are free of chytrid?


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## rcteem (Mar 24, 2009)

This is what is killing a lot of the amphibians!!!! There are test you can do on your frogs to see if they have it by sending off their fecal to certified vet.


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## Roadrunner (Mar 6, 2004)

It's a skin swab, not a fecal and it has to be sent to a lab, not a vet. Although a vet may be able to swab the frog and send it off to a lab for testing.


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## frankpayne32 (Mar 17, 2007)

Dane said:


> Tires, boots, soil associated with plant shipments, livestock hooves, It can even cross oceans in bilge water on merchant ships. So, yeah, I would say that hobbyists have played a minimal part on the global stage when it comes to Bd, but who has data to back that up?


Chytrid can be transported by all of the means you stated but unfortunately chytrid was likely introduced to the new world because of irresponsible hobbyists bringing over Xenopus. Don't get me wrong, I wholeheartedly disagree with the governments proposed plan of action but it doesn't change the fact that hobbyists likely started this whole mess.


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## Roadrunner (Mar 6, 2004)

or science as both had them back then and both were responsible for escapes. They were widely used for pregnancy testing? back then. Don't just try and scapegoat the pet industry. And considering the modes of transport, I wouldn't rule out plants as another possible(or coupled) introduction.


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## frankpayne32 (Mar 17, 2007)

frogfarm said:


> or science as both had them back then and both were responsible for escapes. They were widely used for pregnancy testing? back then. Don't just try and scapegoat the pet industry. And considering the modes of transport, I wouldn't rule out plants as another possible(or coupled) introduction.


I'm not. Based on all the information I've heard over the years released pet Xenopus are the most likely culprit. Drug researchers don't have the tendency to release their test subjects into the wild.


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## Roadrunner (Mar 6, 2004)

All it takes is one.


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## rcteem (Mar 24, 2009)

frogfarm said:


> It's a skin swab, not a fecal and it has to be sent to a lab, not a vet. Although a vet may be able to swab the frog and send it off to a lab for testing.


Thanks for the correction...was late when I was typing and a few beers down...lol


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## Ed (Sep 19, 2004)

frankpayne32 said:


> Chytrid can be transported by all of the means you stated but unfortunately chytrid was likely introduced to the new world because of irresponsible hobbyists bringing over Xenopus. Don't get me wrong, I wholeheartedly disagree with the governments proposed plan of action but it doesn't change the fact that hobbyists likely started this whole mess.


 
Hi Frank,

There is some doubt that chytrid evolved with Xenopus (or any other amphibian) and instead is a novel pathogen of all amphibians. (see for example; Population genetics of the frog-killing fungus Batrachochytrium dendrobatidis ? PNAS (full article)). There is a consistently increasing body of evidence leading towards this conclusion. 

People consistently think that a amphibian has to be introduced into the enviroment to infect a region with chytrid... however waste water is also a much more probable vector as the waste water and street run off all use the same pathways. In many cities under heavy rainfall or snow melt, the sewers often overload resulting in untreated waste water being discharged into the enviroment allowing for an alternate pathway for chytrid introduction. 

(the following is not aimed at you Frank but a general discussion point) 

People should also be leery of putting too much weight on the soil/feather arguments as those studies were done under ideal sterile conditions in the lab and the fungus was not exposed to other factors such as other conditions or competition (including but not limited to microbes, UV light, dessication, or even passive defenses such antimicrobial defenses excreted by the oil gland of birds and then preened into the feathers). Many things that can occur under ideal conditions in a lab are not a feasible option in the wild. 

There is a lot of indication that people have assisted the spread of chytrid within the US (see the above link I provided for Frank for one example). At this point, there is little value in attempting to point fingers for presumed guilt in who released chytrid as both as likely to have occured. Xenopus were present in the pet trade back in the 1950s as well as in labs, at that point both groups were dumping untreated waste water down the drain with little thought towards the long-term possible consequences (much like PCB releases into the enviroment). The hobby needs to take some control and work to prevent further releases as there can be significant differences in lethality between strains and even if one species/locality adapts to a strain, it does not mean that there is conferred immunity to other strains. This means that introduction of several different strains over a course of years could further increase the rate of extinction. This is as simple as not dumping water down the drain without treating it with bleach and discarding all solids via double bagging into the appropriate waste stream and not composting it or dumping it outside. 

Ed


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## frankpayne32 (Mar 17, 2007)

frogfarm said:


> All it takes is one.


Of course it is possible but is by far the more unlikely scenario.


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## johnc (Oct 9, 2009)

frankpayne32 said:


> I'm not. Based on all the information I've heard over the years released pet Xenopus are the most likely culprit. Drug researchers don't have the tendency to release their test subjects into the wild.


Frank, with all due respect, you are not getting a grasp on how chytrid is spread. As Ed points out:



Ed said:


> People consistently think that a amphibian has to be introduced into the enviroment to infect a region with chytrid... however waste water is also a much more probable vector as the waste water and street run off all use the same pathways.


At one point in time, Xenopus were the main form of pregnancy test provided by health professionals throughout the developed world. If Xenopus is the main vector for the disease (one school of thought is that it has always carried the disease) then Chytrid was being released on an ongoing basis in the waste water from every hospital and major doctor practice in the country at one point in time.

Placing blanket blame as you have on hobbyists isn't fair, and it is plain incorrect. Unfortunately, the "anti-pet" lobby will take quotes like yours and throw them around as more reasoning as to why amphibian transport should be banned.


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## frankpayne32 (Mar 17, 2007)

Ed said:


> Hi Frank,
> 
> There is some doubt that chytrid evolved with Xenopus (or any other amphibian) and instead is a novel pathogen of all amphibians. (see for example; Population genetics of the frog-killing fungus Batrachochytrium dendrobatidis ? PNAS (full article)). There is a consistently increasing body of evidence leading towards this conclusion.
> 
> ...


Good article, thanks. I wonder if both could be true. Meaning it could be a novel pathogen and also exotic and more lethal variants were introduced from the old world into the new causing the recent increase in mortality. I have been treating chytrid in captive amphibian populations since 2005 and I have certainly noticed a difference in lethality between strains. I have seen some strains that produced 100% mortality while others produced 0%. Couple this with the fact that some species can carry and transmit it asymptomatically and we have a real can of worms.

You are right that it is useless to point fingers at this juncture. It's all just conjecture on both sides anyway in terms of origin. I have just seen so many unconscionable acts perpetrated by individuals in the herp trade over the past twenty or so years that I tend to blame these bad eggs right away. It's a shame, as there are some really dedicated and conscientious individuals in the herp trade. Sadly, I'd say they are outnumbered by at least 10-1.


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## johnc (Oct 9, 2009)

frankpayne32 said:


> I have certainly noticed a difference in lethality between strains. I have seen some strains that produced 100% mortality while others produced 0%.


You've had the strains distinguished by a microbiologist?


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## Ed (Sep 19, 2004)

Hi Frank,

There is a recent paper that actually argues that chytrid may have originated in the US and the global spread was in part due to bullfrogs.. 

See The Deadly Chytrid Fungus: A Story of an Emerging Pathogen 

The expansion into novel populations may have allowed various strains to increase in lethality as this is selected for rapid expansion of the organism. (think bubonic plague, some flu strains.. as examples). 

Ed


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## mantisdragon91 (Jun 2, 2010)

frankpayne32 said:


> Chytrid can be transported by all of the means you stated but unfortunately chytrid was likely introduced to the new world because of irresponsible hobbyists bringing over Xenopus. Don't get me wrong, I wholeheartedly disagree with the governments proposed plan of action but it doesn't change the fact that hobbyists likely started this whole mess.


Slight correction on that. Not hobbyists but labs since the frogs were previously used as a mobile pregnancy test. Add the urine of a pregnant female to the water and the frogs will attempt to mate. But as always the hobby gets the blame.


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## frankpayne32 (Mar 17, 2007)

johnc said:


> Frank, with all due respect, you are not getting a grasp on how chytrid is spread. As Ed points out:
> 
> 
> 
> ...


Well, with all due respect to you, I have a more than average grasp on how fungal pathogens can and cannot be spread. What is your background in biology? How many times have you successfully diagnosed and treated chytrid? How much have you worked with AmphibianArk as well as other professionals studying and treating chytrid? It is my opinion, as well as other professionals working on the problem, that live Xenopus released into the wild are a more probable"patient zero" then waste water from hospitals. Even if that waste water was improperly treated. But, again like I've said in a previous post, I agree that it is more or less useless conjecture to try to definitively say one way or the other in terms of origin. Also, as I've stated I've been treating chytrid in captive populations since 2005. In fact, I was the first zoo professional to treat chytrid using itraconazole on dendrobatids. So again, this is just my opinion, but I believe my opinion holds more weight than those that may have read a few articles online. If others (anti-pet) take my comments out of context and use that as ammo for their cause so be it. I'm not gonna twist things to suit my purposes.


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## frankpayne32 (Mar 17, 2007)

johnc said:


> You've had the strains distinguished by a microbiologist?


No, just different populations of animals diagnosed with chytrid that exhibited different mortality rates.


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## frankpayne32 (Mar 17, 2007)

Ed said:


> Hi Frank,
> 
> There is a recent paper that actually argues that chytrid may have originated in the US and the global spread was in part due to bullfrogs..
> 
> ...


That's possible, but that's the first source I've seen that argues against it originating in the old world. But, who knows, maybe more info will be discovered that will change things.


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## Ed (Sep 19, 2004)

frankpayne32 said:


> . Also, as I've stated I've been treating chytrid in captive populations since 2005. In fact, I was the first zoo professional to treat chytrid using itraconazole on dendrobatids. So again, this is just my opinion, but I believe my opinion holds more weight than those that may have read a few articles online. If others (anti-pet) take my comments out of context and use that as ammo for their cause so be it. I'm not gonna twist things to suit my purposes.


 
The first treatments of chytrid in dendrobatids with itraconazole were reported in the literature as early as 2002 as cited in the full document here 
http://www-lbtest.jcu.edu.au/school/phtm/PHTM/frogs/papers/lamirande-2002.pdf These were also Zoo professionals. 

In addition, there was a lot of initial work done by other Zoo professionals such as Dr. Pessier.. and others in both the documentation of susceptiability, diganosis and treatment of dendrobatids pre-2005... 

If you are indicating that all I've done is read a few papers and have not been involved with treatments of anurans in professional setting you are barking up the wrong tree... 


Ed


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## frankpayne32 (Mar 17, 2007)

Ed said:


> The first treatments of chytrid in dendrobatids with itraconazole were reported in the literature as early as 2002 as cited in the full document here
> http://www-lbtest.jcu.edu.au/school/phtm/PHTM/frogs/papers/lamirande-2002.pdf These were also Zoo professionals.
> 
> In addition, there was a lot of initial work done by other Zoo professionals such as Dr. Pessier.. and others in both the documentation of susceptiability, diganosis and treatment of dendrobatids pre-2005...
> ...


Well then I have my facts wrong. I was told that it was the first succesfull treatment using that method outside of a lab. Guess I was told wrong.


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## johnc (Oct 9, 2009)

frankpayne32 said:


> No, just different populations of animals diagnosed with chytrid that exhibited different mortality rates.


Sorry if this is beginning to look like the "let's have a go at Frank" thread but if you haven't had scientific testing done to show that there are multiple strains involved, please do not make assumptive scientific statements about it. It doesn't give us new facts and it actually helps to misinform other hobbyists and in turn it leads to new unqualified assumptions.


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## rcteem (Mar 24, 2009)

johnc said:


> Sorry if this is beginning to look like the "let's have a go at Frank" thread but if you haven't had scientific testing done to show that there are multiple strains involved, please do not make assumptive scientific statements about it.  It doesn't give us new facts and it actually helps to misinform other hobbyists and in turn it leads to new unqualified assumptions.


not to mention our government!!!


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## frankpayne32 (Mar 17, 2007)

johnc said:


> Sorry if this is beginning to look like the "let's have a go at Frank" thread but if you haven't had scientific testing done to show that there are multiple strains involved, please do not make assumptive scientific statements about it. It doesn't give us new facts and it actually helps to misinform other hobbyists and in turn it leads to new unqualified assumptions.


It's no problem, you can have a go at me all you want. I'll be happy to take it and answer all questions and respond to all statements. If I misspoke or am flat out wrong, as I am a lot of the time, like everyone else, I will own up to it when it is pointed out. However, in this case you are making the assumption not me. I never said that what I have seen are genetically different strains, you assumed that's what I meant. I was simply saying that I have seen different populations of amphibians in captivity that were positively diagnosed with chytrid that experienced vastly different mortality rates.


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## johnc (Oct 9, 2009)

frankpayne32 said:


> I was simply saying that I have seen different populations of amphibians in captivity that were positively diagnosed with chytrid that experienced vastly different mortality rates.


You used the word strain though so that set off alarm bells.


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## frankpayne32 (Mar 17, 2007)

johnc said:


> You used the word strain though so that set off alarm bells.


I see...perhaps I should have used a different word. Do you not think that there are multiple variants of chytrid? If so, why?


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## johnc (Oct 9, 2009)

frankpayne32 said:


> I see...perhaps I should have used a different word. Do you not think that there are multiple variants of chytrid? If so, why?


I don't just think it, I know it. There are multiple strains of the fungus as shown by several peer reviewed journal articles. You said the word strain and that means genetic variation. That's what I was picking up on. You can't use the word strain in a hand-waving sense as you did and not expect to be pulled up on it, especially since you've got "Science Teacher" in your signature.


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## Baltimore Bryan (Sep 6, 2006)

Sorry if this was already posted and I missed it, but what ever happened to the TWI chytrid test? Did they ever get enough samples in to test them? I think that could be useful to reference that many of us hobbyists are trying to be responsible and are even having our collections tested to understand how/if Bd is found in our personal collections.
Bryan


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## Dendro Dave (Aug 2, 2005)

Ed said:


> Hi Frank,
> 
> There is a recent paper that actually argues that chytrid may have originated in the US and the global spread was in part due to bullfrogs..
> 
> ...


Has this info and other relevant papers been forwarded to the USFWS? Seems like it would be good for someone with credentials to do that if it hasn't been done already. Didn't they specifically request this kind of info? Could go a long ways in supporting our position that this law would do more harm then good.


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## Ed (Sep 19, 2004)

Dendro Dave said:


> Has this info and other relevant papers been forwarded to the USFWS? Seems like it would be good for someone with credentials to do that if it hasn't been done already. Didn't they specifically request this kind of info? Could go a long ways in supporting our position that this law would do more harm then good.


 
Hi Dave,

I suspect USF&W has it already, however we have to keep it in context that the data can be argued both ways.. as a hypothetical example, it references that populations of some species and chytrid may be coevolving to a less lethal strain in some localities, yet continued introductions from abroad of other strains would disrupt that evolving equilibrium and could result in the loss of more animals in isolated localities or even species. 

There was a response to the "Out of Africa" hypothesis for chytrid pointing out a lot of the flaws in the theory but I can't find it now.. 

Ed


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## illinoisfrogs (Apr 16, 2010)

frankpayne32 said:


> It's a shame, as there are some really dedicated and conscientious individuals in the herp trade. Sadly, I'd say they are outnumbered by at least 10-1.


Strongly disagree.....you must hang out with some poor herpetologists! I see the reverse, about 1 bad one for every 10 good ones....


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## skylsdale (Sep 16, 2007)

Baltimore Bryan said:


> Sorry if this was already posted and I missed it, but what ever happened to the TWI chytrid test? Did they ever get enough samples in to test them? I think that could be useful to reference that many of us hobbyists are trying to be responsible and are even having our collections tested to understand how/if Bd is found in our personal collections.


chytrid study | Tree Walkers International


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## frankpayne32 (Mar 17, 2007)

johnc said:


> I don't just think it, I know it. There are multiple strains of the fungus as shown by several peer reviewed journal articles. You said the word strain and that means genetic variation. That's what I was picking up on. You can't use the word strain in a hand-waving sense as you did and not expect to be pulled up on it, especially since you've got "Science Teacher" in your signature.


I'm sorry, I'm still confused. What do you know? That there are or are not multiple strains of chytrid? And also, I've answered all of your questions and responded to all of your comments in this thread. I wish you would do the same. And to further clarify me previous statements. When I said "strains" I made a reasonable guess that what I was seeing in real life (not just reading papers) was the presence of multiple strains. I do not claim that I know for a scientific fact that I was experiencing multiple strains but it is my best guess based on actual experience.


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## frankpayne32 (Mar 17, 2007)

lincolnrailers said:


> Strongly disagree.....you must hang out with some poor herpetologists! I see the reverse, about 1 bad one for every 10 good ones....


You are lucky then. But I am not talking about herpetologists but rather people in the herp trade. Two completely different groups of people. Like you said herpetologists are generally a great group. I was just referring to most people that own reptiles and amphibians.


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## johnc (Oct 9, 2009)

frankpayne32 said:


> I'm sorry, I'm still confused. What do you know? That there are or are not multiple strains of chytrid? And also, I've answered all of your questions and responded to all of your comments in this thread. I wish you would do the same. And to further clarify me previous statements. When I said "strains" I made a reasonable guess that what I was seeing in real life (not just reading papers) was the presence of multiple strains. I do not claim that I know for a scientific fact that I was experiencing multiple strains but it is my best guess based on actual experience.


Quite a heavy edit there Frank . We know there are multiple strains in the US. Strain implies genetic differentiation. Look it up. I was taking you to task because you stated you had seen different strains yet you had no diagnostic tool to make that judgement.


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## frankpayne32 (Mar 17, 2007)

johnc said:


> Quite a heavy edit there Frank . We know there are multiple strains in the US. Strain implies genetic differentiation. Look it up. I was taking you to task because you stated you had seen different strains yet you had no diagnostic tool to make that judgement.


Sigh, I don't even know what you mean by heavy edit. Can't someone reread their words and fix mistakes anymore without a disparaging comment being made?

And, again, I sigh at your general lack of courtesy and your sidestepping of points. This dialog is quickly devolving and becoming just frustrating. Instead of focusing on the points I am trying to make you are picking apart my words that are quickly being typed on an internet forum. Also, I do not need to look up what a strain is but you obviously need to familiarize yourself with civility in an open forum. Again I will say, I fully admit that I have no scientific proof, only an educated guess that what I was seeing were different strains. I have no proof for that and I do not claim to. I only have an educated and reasonable assumption based on what I was observing. Again, in the real world, not on paper. Since you ignored it last time, I will ask again: How much experience do you have with observing and treating chytrid?


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## Freeradical53 (Jan 25, 2008)

I have caught up on the "discussion". IMHO the ban of imports or transportation of amphibs between states that have chytrid is a good thing. However, to ban all such transfers is unnecessary. Test them and you won't have a problem with the spread of the disease from at least that source. Whether or not these animals reacquire the disease from other sources after testing is something that no one can predict or do anything about.


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## frankpayne32 (Mar 17, 2007)

Freeradical53 said:


> I have caught up on the "discussion". IMHO the ban of imports or transportation of amphibs between states that have chytrid is a good thing. However, to ban all such transfers is unnecessary. Test them and you won't have a problem with the spread of the disease from at least that source. Whether or not these animals reacquire the disease from other sources after testing is something that no one can predict or do anything about.


I agree to an extent. Except that a law only allowing the transport of tested animals will still in effect ban the transport of the animals in most cases anyways. In order for a wholesale ban like this to be effective all plants with soil around their root balls would also need to be banned, etc.


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## Ed (Sep 19, 2004)

frankpayne32 said:


> I agree to an extent. Except that a law only allowing the transport of tested animals will still in effect ban the transport of the animals in most cases anyways. In order for a wholesale ban like this to be effective all plants with soil around their root balls would also need to be banned, etc.


The soil (and feather) hypothesis can be viewed here http://www.jcu.com.au/school/phtm/PHTM/frogs/papers/johnson-feathers-2005.pdf 

People should note that in both the case of the soil and feather, both are 
1) sterile (no competition for the pathogen) 
2) lacking other antimicrobial compounds (from the oil preen gland in birds and other microbes in the case of the substrate) 

3) the authors themselves note that these results may not be valid in natural conditions as they do not replicate in vivo conditions. 
4) it is already illegal to transport soil from outside the country into the country without APHIS permits and restrictions. 

Based on the paper, it is certainly too soon to mandate that soil transport between states has to be banned, as there isn't any information as to whether or not the study replicates results found in the natural enviroment. There had prior to that point been a lot of speculation that chytrid could be transported in moist soils particularly if the substrates were recently contacted by a infected frog but we still don't have the data to say that it does occur. In addition, the USDA has already ruled that chytrid is "non-actionable" meaning that soil transport would not be banned. 

For those who have not made any comments, consider looking at the PIJAC action statements

http://www.pijac.org/_documents/us_pijac_drafting_points_for_fws_comments_-_bd_phibs_2010.pdf for some ideas on what to stress. In any case, do not cut, copy and paste as this will have much less weight than a simple well reasoned comment. 

Ed


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## frankpayne32 (Mar 17, 2007)

Ed said:


> The soil (and feather) hypothesis can be viewed here http://www.jcu.com.au/school/phtm/PHTM/frogs/papers/johnson-feathers-2005.pdf
> 
> People should note that in both the case of the soil and feather, both are
> 1) sterile (no competition for the pathogen)
> ...


Well, I have first hand experienced chytrid being introduced into a dendrobatid exhibit via untreated soil from new plants. And before someone ask, no, I do not have double blind, peer reviewed scientific proof. But, the frogs did not have chytrid previously to the introduction of the new plants. All other variables were eliminated to the best of my ability in a non-laboratory setting.


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## frankpayne32 (Mar 17, 2007)

Ed, if you don't mind could you direct me to your own comments on the issue? In all honesty I am very ambivalent on the topic and I would value your opinion and insight.


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## johnc (Oct 9, 2009)

Frank, I meant no offense to you. Let me explain. I have taken you to task because you've used incorrect terminology/phraseology and you state in your signature that you are a "Science Teacher". Many of us on here are professional scientists (I am such, though I don't advertise it) and I find it very difficult to tolerate inaccurate terminology, and plain disinformation, from someone who goes out of their way to label themselves as a scientist. I am very passionate about good science.


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## frankpayne32 (Mar 17, 2007)

johnc said:


> Frank, I meant no offense to you. Let me explain. I have taken you to task because you've used incorrect terminology/phraseology and you state in your signature that you are a "Science Teacher". Many of us on here are professional scientists (I am such, though I don't advertise it) and I find it very difficult to tolerate inaccurate terminology, and plain disinformation, from someone who goes out of their way to label themselves as a scientist. I am very passionate about good science.


If you meant offense or not does not change the fact that you were being rude. By repeatedly saying "taking you to task" which literally means to scold to another adult is flat out rude and denigrating. And I'm going to have to continue to say that I did not use incorrect terminology. It is my opinion that I encountered distinct strains of chytrid. I fully admit and have never claimed otherwise that I do not have proof to back up my opinion. In all of the cases that I am referring to the animals were diagnosed with chytrid by an outside lab. Distinctions between strains were not made. I have only made an educated guess based on direct observations. So despite our disagreement on my use of terminology what disinformation have I presented? Also, to further clarify, I have never claimed to be a scientist. I don't use that term lightly and to my recollection I have never referred to myself as such. To me, a scientist, is someone whose job it is to do original research. The only research I did was in college and grad school. As you have pointed out several times I am a high school science teacher and I call myself such. I guess I do go out of my way to advertise what I do for a living. I am proud of all three jobs I hold down at once.


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## Rain_Frog (Apr 27, 2004)

First and foremost-- all the effort writing on this thread could (not saying nobody writing on these threads isn't) be put towards writing an actual letter to the USFWS. I am nearly finished with mine.

Hi Ed,

I haven't had a chance to read the paper, but I have heard that there was one study showing that there was a chytrid strain that possibly coevolved with Andrias in Japan.


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## Ed (Sep 19, 2004)

frankpayne32 said:


> Well, I have first hand experienced chytrid being introduced into a dendrobatid exhibit via untreated soil from new plants. And before someone ask, no, I do not have double blind, peer reviewed scientific proof. But, the frogs did not have chytrid previously to the introduction of the new plants. All other variables were eliminated to the best of my ability in a non-laboratory setting.


 

Hi Frank,

There are alternative methods for chytrid to have been introduced into the enclosures.. 

How did you identify that the chytrid did not come in through 

1) the water supply
2) via transmission on human hands? 

There are anecdotal reports from reliable sources (example with Wyoming toads (USF&W research station) had a chytrid outbreak that was tracked back to the new water supply and there is some indication in the literature that chytrid can survive in tap water (note the following paper was in a lab setting, and the water was autoclaved which could have changed chlorination levels) http://eprints.jcu.edu.au/6267/1/6267_Johnson_&_Speare_2003.pdf 
(this is one of the papers where recommendations on soil were made as a most conservative measure to prevent further transmission with no follow up data). 

There is also adequate information that chytrid can survive for short periods on human skin and be transferred in that manner. The same can also be said for gloves. See http://www.wbwg.org/conservation/papers/chytrid_Mendez_DAO.pdf 


Based on the above studies, it is also a hypothetical possibility that chytrid came into the enclosures through the regular water supply. Washing plants, materials, hands, wetting gloves, with tap or well water could have supplied the secondary infection into the enclosure. With respect to the enclosures, if you are not the only person accessing them (say on your days off), then there is another potential source of contaminination. 

This is why we have to be careful when assessing blame on how chytrid got into an enclosure or even a wild population. In many cases, Occam's razor is a good tool to make a determination but when there are other simple possibilities we can't rule them out as well. 

Ed


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## Ed (Sep 19, 2004)

Rain_Frog said:


> First and foremost-- all the effort writing on this thread could (not saying nobody writing on these threads isn't) be put towards writing an actual letter to the USFWS. I am nearly finished with mine.
> 
> Hi Ed,
> 
> I haven't had a chance to read the paper, but I have heard that there was one study showing that there was a chytrid strain that possibly coevolved with Andrias in Japan.


 
Hi Doug,

There is some serious doubt as to that conclusion that they coevolved together over a long period of time. If I remember some of the discussion around that report, the decision of coevolution may be premature.. It is interesting that Bd was not detected anywhere in Asia (and was thought to not have been present in Asia) even though there was a lot of effort and then all of a sudden multiple "coevolved" strains were discovered. 
A lot of caudates tested in the US are relatively resistent to chytrid acting as carriers for the fungus. In addition in some caudates the associated microbial fauna allows them to resist or clear the fungal pathogen. 
I'm withholding my acceptance of that conclusion particularly with the variation we are seeing in both lethality, genetic variability (such as that seen in bullfrogs) and distribution as more data emerges. I have to add that we are seeing rapid coevolution in some populations (that appear to not have repeated exposures to novel to that population strains) and species (and some species just don't seem to make it through the first round or two of exposure). See the paper I referenced earlier in the thread on what is happening in the Sierra Nevadas so that also casts some doubt on the idea that is has been present all along.. 

Ed


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## Ed (Sep 19, 2004)

frankpayne32 said:


> Ed, if you don't mind could you direct me to your own comments on the issue? In all honesty I am very ambivalent on the topic and I would value your opinion and insight.


 
I have not posted my comments on the topic here.. 

My thoughts on it are probably different than a lot would expect as I have experience in three main areas of dealing with amphibians in captivity 
1) as a private hobbyist
2) as a Zookeeper specializing in amphibians (for almost 2 decades)
3) working in the pet industry (where I did whole sale orders for a store for many years) 
4) I also worked in a ASPCA. 

So I see it from a mix of viewpoints. 

I personally do not see the need for interstate regulations on chytrid as long as there is a reasonable attempt by the hobbyists to regulate thier waste products to prevent further spread of the disease, as I noted above this is very simple (but I am willing to bet that most people here don't do either of them). I am more concerned about the strains with a higher lethality that occur in other parts of the world. For example, if the strain currently moving through Central America that is killing more than 95% of all amphibians in its path (including caudates) gets loose in the US, the prospects for some stabilizing populations would become even more dire. I am more ambivalent on the import issue due to the high risk. 

I am also more concerned with the potential risk posed by ranaviruses that are being transported around the world. Chytrid may cause amphibian mortality but some of the ranaviruses have been reported to not only kill amphibians but fish, reptiles and invertebrates in novel population introductions.

I also do not buy into the banning agenda conspiracy that has been floating around for awhile...


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## JJuchems (Feb 16, 2004)

johnc said:


> Response to what? They have already posted information about the issue and told us how to comment. In fact part of my post was lifted from their information.


Can you point me to this information? I receive their emails (no emails in at least a month on this topic and they just sent one on S373), and can not find it on their site. I called Andrew Wyatt, his voice mail is full. I have emailed with no response. They have not sent an email stating the deadline is quickly approaching, similar to what they did for S373 or HR669. The dissemination of information is not the same, actions speak louder than words.


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## frankpayne32 (Mar 17, 2007)

Ed said:


> Hi Frank,
> 
> There are alternative methods for chytrid to have been introduced into the enclosures..
> 
> ...


True, and I do submit that I am not 100% sure that it came in through soil but I still believe it did. This is why:

-This was on a display exhibition that was recently set up. There were over a dozen separate exhibits of amphibians that were in the same exhibit gallery but they were not connected and had their own filtration systems.
-I was literally the only person servicing the exhibits. 
-Each exhibit was more or less set up as "quarantine" with separate tools, use of gloves, etc.
-Only the one exhibit had plant die off and received new plants with new soil.
-All exhibits were tested for chytrid. Only one had it (the one with new plants added).
-The water source was run through a 5 stage RO-DI and UV filtration system. Each exhibit also had it's own UV sterilizer.

So, while I concede that it is hypothetically possible that the fungus was introduced by some other method I think it is highly unlikely.


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## frankpayne32 (Mar 17, 2007)

Ed said:


> I have not posted my comments on the topic here..
> 
> My thoughts on it are probably different than a lot would expect as I have experience in three main areas of dealing with amphibians in captivity
> 1) as a private hobbyist
> ...


Ed,

Thank you for your comments. While I do not have your level of experience I also see it from two similar perspectives: as a herpetology keeper and a private hobbyists and because of this have somewhat conflicting opinions.

I only encountered ranavirus once in a captive population but it did produce a 100% mortality in a population of Theledoerma corticale. Certainly an overlooked problem.


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## JJuchems (Feb 16, 2004)

I just spoke with Andrew Wyatt USArk will be sending an email soon to get people informed. 

Sent from my SPH-M900 using Tapatalk


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## TDK (Oct 6, 2007)

ALERT: DEADLINE Public Comment Amphibian Listing!
DEADLINE Thursday December 16, 2010
The deadline for the USFWS public comment period regarding the the listing of ALL Amphibians on the Injurious Wildlife list of the Lacey Act is NEXT Thursday at 11:59 PM. EVERYONE NEEDS TO COMMENT!!
The following are guidelines from USARK to the Reptile Nation on “How To” make a highly effective public comment on the USFWS Notice of Inquiry (NOI) entitled, Injurious Wildlife Species; Review of Information Concerning a Petition To List All Live Amphibians in Trade as Injurious Unless Free of Batrachochytrium dendrobatidis. It is extremely important that you make public comment! Your comments should be thoughtful and pertinent. Please DO NOT plead for your animals, complain about fairness, or give your political philosophy regarding regulation. If you have put a lot of thought and effort into your comments please email to USARK so we can see them. Read below for the best suggestions of “How To” make public comment.
***If you know any government agency scientists, university academics, veterinarians or zoo professionals please request they make public comment by the deadline!!!

USARK Recommendations for Making Public Comment:
• It is highly suggested that your comments be original and written by you. There seems to be confusion about ‘How To’ and ‘Where To’ make comment. The following is ‘step by step’ on how to make a fast and easy comment: 
1. Go to the government portal. 
2. Fill in the fields for Name, Country, City and Postal Code. Ignore the rest of the fields. 
3. Copy the Sample Letter below. Modify it with your own comments (HIGHLY SUGGESTED). Save it into a Word, Works, Note Pad or PDF file. Click the Browse button on the Attach File field and download your file. (you can not cut & paste more than 2000 characters into govt portal) 
4. If you are a business copy Sample Letter onto company letterhead and save as a Word, Works, Note Pad or PDF file. Click the Browse button on the Attach File field and download your file. (if you are NOT a business skip step 4) 
5. Click Submit button. You're Done! (If you are successful you will get a confirmation number)
***If your comment is more than 2000 characters save it to a Word file or PDF and use the 'Attach File' field at the government portal to upload your document.
-------- CLICK HERE TO GO TO GOVERNMENT PORTAL -------- Regulations.gov 

SAMPLE LETTER: (Copy Into Word file or PDF- Please edit & make your own- submit through link above)
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,
As a supporter of the United States Association of Reptile Keepers (USARK) and someone who is concerned about the environment, I am writing today to OPPOSE the Petition To List All Live Amphibians in Trade as Injurious Unless Free of Batrachochytrium dendrobatidis as submitted by the Defenders of Wildlife and posted to the Federal Register as a Notice of Inquiry (Federal Register /Vol. 75, No. 180 / September 17, 2010).
I am very concerned about the economic impact of listing all amphibians on the Injurious Wildlife list of the Lacey Act; and what it would mean to my business and ability to support my family. The precautionary principle recommended by the Defenders of Wildlife endorses a guilty until proven innocent approach that reveals a more ideological motivation. The Lacey Act was not designed to be used as is being proposed. Never was it intended to include native animals or micro organisms that could potentially be hitch hikers. Never have so many animals, so widely held and traded by the American public been proposed for listing. Defenders of Wildlife cannot possibly be unaware of these facts, nor the cost prohibitive testing that would have to be done to comply with such a listing. The Lacey Act is an inflexible, ineffective tool which will do little to address problems in wild populations, while making millions of Americans potential felons, and devastating thousands of small businesses.
USARK has developed Best Management Practices in an effort to secure animals in captivity and mitigate risk of contributing to problems in wild populations. Secure containment and environmental protocols ensure minimal risk from the Herp Industry and pet owners. Small business’ like mine, while having nothing to do with the spread of chytrid fungus in the wild, take more precautionary measures and would potentially be more impacted by a listing than any other stake holder group. The inability of Lacey Act to focus on actual problems and provide pragmatic remedy reinforces that it is an inappropriate tool to address this issue. Our animals are valuable and securely contained. They will never be exposed to wild populations.
I don’t believe that FWS has the resources or ability to enforce an unprecedented listing with such far reaching implications. It seems to me that FWS already struggles to administer the duties with which it has already been tasked. I understand the mandates under which FWS must respond to the petition fielded by Defenders of Wildlife, but they are attempting to redefine Lacey Act into a tool to change the way America looks at and treats animals. It is not the job of our federal government to satisfy the ideological goals of a powerful special interest group. A listing of this nature would negatively impact my family and business.
Sincerely,

usark.org
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## Tex22seg (Dec 3, 2010)

this is a must. spreed the word put it on every form including reptile forms.


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## earthfrog (May 18, 2008)

TDK said:


> ALERT: DEADLINE Public Comment Amphibian Listing!
> DEADLINE Thursday December 16, 2010
> The deadline for the USFWS public comment period regarding the the listing of ALL Amphibians on the Injurious Wildlife list of the Lacey Act is NEXT Thursday at 11:59 PM. EVERYONE NEEDS TO COMMENT!!
> The following are guidelines from USARK to the Reptile Nation on “How To” make a highly effective public comment on the USFWS Notice of Inquiry (NOI) entitled, Injurious Wildlife Species; Review of Information Concerning a Petition To List All Live Amphibians in Trade as Injurious Unless Free of Batrachochytrium dendrobatidis. It is extremely important that you make public comment! Your comments should be thoughtful and pertinent. Please DO NOT plead for your animals, complain about fairness, or give your political philosophy regarding regulation. If you have put a lot of thought and effort into your comments please email to USARK so we can see them. Read below for the best suggestions of “How To” make public comment.
> ...


I signficantly revised the letter from its original format (emboldened above) in terms of grammatical structure and spelling in order to make it more professional. I also deleted a 'personal defense of animals/interest' sentence or phrase somewhere in there and added one about dart frogs. I suggest using this new copy to send to the appropriate recipients, but also edit it to suit your needs.


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## johnc (Oct 9, 2009)

From another thread.

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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