Courtesy of Shawn K. Heflick
August 23, 2006
Subject: FWC Public Comment Meeting Summary, Ft. Lauderdale, FL
Greetings Herpers!
The public comment meeting for the Rulemaking Process on Reptiles of Concern and Venomous Reptiles (among other things) was extremely well attended last evening in Ft. Lauderdale. The meeting was conducted by Captain Linda Harrison and Captain John West of FWC. They did a great job of answering questions, providing a floor for comments (I had my fare shareJ), and noting suggestions. There were some great comments and a lot of great dialogue between the reptile community present and FWC. During the entire forum they emphasized the role and desire for public input into the process. If you attend any of the remaining meetings (times and addresses included below), be sure to sign up to speak at the beginning of the meeting, even though by the time they get to you, you may decide not to speak…though they provide ample time for comments/questions.
A synopsis follows:
1. FWC defined Reptiles of Concern (ROCs): 5 species of giant snakes (Amethystine, Burms/Indians, Retics, Anaconda, African Rocks) Nile monitors, Water monitors and Tegu lizards. When questioned why Tegus were included, they said there was a sustaining population in Polk County living in Gopher Tortoise burrows. FWC stated that it is very likely that Tegus may not be a problem and the regs will reflect it if that is the case. Discussion on Morph specimens not being included in the Reptiles of Concern followed. Comment was made by FWC that “equal” numbers of morphs/non-morphs have been found in urban settings, so the topic is in need of review. I find this “equal numbers” suspect and hard to believe based on % of overall captive population…let alone the value angle.
FWC admits that releases appear to be the result of all impulse buys by the uninformed public who then become uninterested in their pet reptile, which spurred myself and many retailers/wholesalers/breeders present to suggest that it was a consumer based problem and thus the end consumer should be burdened with the permitting, etc. (Excerpt from Bill Brant’s letter: The defining point could be the issue of sales tax. If a person has a Florida sales tax certificate so they can re-sell the reptile of concern they would not bear the burden of identifying the reptile of concern. A large number of the ROCs sold are never going to reside in Florida and therefore do not threaten the Florida environment. All of that paperwork and identification required would be unnecessary. The permit holder would be the consumer who is the one probably releasing them into the environment anyway. I am doubtful that breeders, importers and distributors are releasing”…based on monetary issues). Many of us added in this meeting that the financial burden of such permitting on large breeders/wholesalers/distributors would be astronomical and thus an unfair burden for the people not responsible for the end result wild release. The FWC seemed to have already been considering this and agreed that end user/consumer maybe the way to go.
2. The floor was opened to the first speaker who was an animal rights activist who basically wanted all exotics banned…we, the reptile community, did well in not justifying his comment with a response…WELL DONE ALL…I know you wanted toJ
3. The requirement of a PIT tag for Reptiles of Concern and non-indigenous venomous reptiles was another huge topic in this forum. We commented on the incomprehensibility of attempting to place PIT tags in many of the species that were small or extremely venomous and thus problematic for most to lay their hands on. In addition, neonates/hatchlings of most venomous species are far smaller than what is acceptable for implantation of these devices, thus the negative impact of the micro-chip on neonate animals would be counterproductive. My initial comments also included the risk to the person administering the PIT tag, along with the (typically unqualified) vet assistance needed and the lack of veterinarians willing to tag venomous reptiles. An alternative means of identification such as digital photographs was added as, though not perfect, a more reasonable and cheaper form of ID. Comments underlining the fact that the venom producers and wholesalers would be placed under undue burden to microchip all of the venom production stock was also interjected. This may ultimately lead to a loss of venom production and subsequently diminish the supply of anti-venom in the state. Many submitted that FWC themselves would be burden with a huge cost of regulating and tracking such a system beyond their already labored efforts to stay abreast of the current paperwork.
4. Additional Topics:
A. Additional topics we added concerned caging requirements that don’t seem to take into account individual species that should be reviewed. Minimum size caging for neonate balls was on a lot of people’s minds and their need for dark, confined spaces. Most breeders have neonate racks that do not currently meet these standards. Natural history of this species and current breeding/housing success would conclude that this is in need of review.
B. The inclusion of environmental controls is another topic we brought up as short-sighted. Many breeders have rooms that are climate controlled and meet or exceed the environmental conditions necessary to successfully keep reptiles. The inclusion of lights in snake species is physiologically unnecessary and may be detrimental to some species overall wellbeing (Ball Pythons). Many nocturnal species like the dark and are impacted negatively by direct lights in the enclosure.
C. The need for paperwork submission EVERY THREE MONTHS was also on my list. The proposed regs would require licensees to submit acquisition/deposition paperwork on ALL animals every 90 days. Who/Where/When it came from and who/where/when it went to. For large breeders/wholesalers/distributors this may boil down to thousands of animal acquisitions/dispositions per month. I believe I was clear in my delivery that this not only places unrealistic deadlines on licensees, but further burdens the FWC with mountains of paperwork in addition to their already, shall we say untimely and far from mistake proof, mounds of paper in place currently. It was suggested that at most every 6 months was more than enough to accomplish the goal desired.
D. Lastly, we brought up the need for clear written regulations for venomous exhibition at shows/expos, so that all of the guesswork can be taken out of the process and vendors are not stressed/burdened/reprimanded by paying the price for unclear regs.
REMEMBER, FWC IS ASKING FOR OUR INPUT. MANY STATES JUST SHUT IT ALL DOWN (KENTUCKY). PARTICIPATE, VOICE YOUR OPINIONS, BE HEARD, BE SEEN, BE A POSITIVE PART OF THE ANIMALS AND THE INDUSTRY WE ALL LOVE.
WHEN you go…thank FWC for giving us an opportunity to voice our opinions!
If you are located in another area of the state please try to attend one of the comment sessions. Next week will be Pensacola and Tallahassee. Please make comment even if you feel others have already said the same thing. They need to hear what people have to say. Please forward this e-mail to other Herpers and people in the reptile industry.
Per Bill Brant…THE WORLD IS RUN BY PEOPLE WHO JUST SHOW UP…he is right!!!
If you would like any additional information or have comments please email me at
sheflick@aol.com.
Cheers,
Shawn K. Heflick
August 22, 2006, 6:00 p.m. - 8:00 p.m.
Tampa Port Authority, 1101 Channelside Drive, 1st Floor Board Room, Tampa, FL 33602
August 23, 2006, 6:00 p.m. - 8:00 p.m.
Broward County Main Library, 100 S. Andrews Avenue, 8th Floor, Rooms 8A & 8B,
Ft. Lauderdale, FL 33301-1830
August 28, 2006, 6:00 p.m. - 8:00 p.m.
Pensacola Junior College, 1000 College Blvd., Hagler Auditorium, Bldg. 2 Room 252, Pensacola, FL 32504-8910
August 29, 2006, 6:00 p.m. - 8:00 p.m.
Florida Fish and Wildlife Conservation Commission, Bryant Building, 620 S. Meridian Street, 2nd Floor, Room 272, Tallahassee, FL 32399-1600
Written comments can be sent to:
FWC
Division of Law Enforcement
Investigations Section
Attn: Ms. Precious Boatwright
620 South Meridian St.
Tallahassee, FL 32399-1600
Deadline is Sept 13, 2006.