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General Comment on:

DEPARTMENT OF THE INTERIOR
Fish and Wildlife Service
50 CFR Part 16
[FWS-R9-FHC-2008-0015; 94410-1342-0000-N3]
RIN 1018-AV68
Injurious Wildlife Species; Review of Information Concerning 
Constrictor Snakes From Python, Boa, and Eunectes genera
AGENCY: Fish and Wildlife Service, Interior.
ACTION: Notice of inquiry.
29 April 2008
To whom it may concern:

My name is Ralph Davis. I am the owner of Ralph Davis Reptiles, LLC. I also run a successful construction company. Being in the construction industry has shown me just how much manufacturing, building and purchasing of supplies goes into the reptile business and how badly the economy would be affected by the loss of revenue spent nationwide to keep reptiles.  I am one of many professional herpetoculturists in The United States who keep and breed constrictors. I have been keeping and breeding constrictors (mainly Ball Pythons) for almost 20 years; the last 8 years you could say have been on a professional level, operating as a business.

My website has been active for ten years and has been visited well over four million times in those ten years. I am a very involved person in the “snake world,” contributing 110% to promote boas and pythons in a professional and positive manner. I have five years worth of daily journal entries on my site as well as countless pages of information including images and videos. There is a very active message board on my site that is visited two thousand times each day by reptile enthusiasts, hobbyists, and professional breeders. I write and communicate on the web very candidly and have become one of the TOP Snake Breeders in the world. I take great pride in my collection of boas and pythons and encourage every person that I come in contact through the same interests to do the same.

I meet with USFW Service many times each year to ship captive produced snakes overseas with CITES permits. I have been a licensed “active” importer/exporter through USFW Service for nine years.

 I have built up and managed a large collection of ball pythons for the purpose of breeding and making “new morphs.” A “morph” is a color mutation or a pattern mutation or both. A “morph” is not your typical colored wild type constrictor, it does not look “normal” in color or pattern.

Boa and Python Morphs have increased in popularity over the past ten years and in my opinion have taken the reptile industry to where it is today ( HUGE! ). There are countless boa and python related internet sites. Reptile communities, reptile portals, message boards, blogs, professional breeder sites, caging manufactures, electronics ( lighting and heating ), feeders, bedding, cage furniture, shipping supplies and the list goes on. This is a HUGE industry fueled by hard working professionals who make their living working with the reptiles that they love.

There are hundreds of publications on the subject of boas and pythons that show them in a much different light, not “Injurious.”  I myself have been featured in many publications for the work that I have contributed with the many other professional “snake breeders.” I have maintained a positive, professional “web presence” for 10 years as have all of the TOP breeders in the country to promote and teach in a responsible professional manner. This is a “real job” for hundreds of thousands of tax paying people and that number is LOW. I’m talking about the breeders of the species all the way down to the guy who shreds wood chips for bedding and everyone in-between. There are thousands of reptile related products and services that will be affected by a ban. The snow-ball affect of a nationwide ban of boas and pythons would be a catastrophe morally and economically.  From the breeder / keeper / hobbyist to the retail shops. A ban would be horrible for the species as it would put the only knowledgeable people working with the species out of business.

People who have put 30 years of their lives into working and understanding the species. Who, through trial and error have established and learned to maintain the species in viable collections. People that zoos and reptile related institutions learn from and most of all collect the data to support the species in captivity. These “reptile people” are no different than the ‘cat people” or the “dog people” or any of the other “pet niches.” Of course there will always be irresponsible owners in any type of the situations. These people seem to be the ones to find the fame through the media and make the other 99% look bad.

Some things that will be affected by a ban:

Reptile shows. There are hundreds across the US each year. Vendors and the public book hundreds of hotel rooms at each event. Parking is paid for, food and drinks are paid for. Airline tickets are paid for. Fuel is paid for. The “arena” is paid for.  Tolls are paid for. Rental fees are paid for. Local media advertising is paid for. The establishments local to the shows benefit greatly from the events with monies in.

Reptile Portals on the internet. Advertising is paid for. Bandwidth and domains are paid for. Sponsorships are paid for. Site maintenance is paid for. Having legal council is paid for. These sites all have people on the payroll. The money to pay the staff is generated by the reptile community who patron the site.

Private breeders maintaining large collections who are the “back bone” of the industry would be crippled. What is to become of a large boa and python collection? A collection that is maintained through money that the breeder makes from selling captive offspring?  Breeder expenses are HUGE.

The cost of the facility, rent, property tax, gas and electric costs, trash removal,  land line and cell phone, computers and software, audio and video equipment. Up-keep and maintenance of the facility and property. Employee payroll, FICA, worker’s comp insurance, liability insurance and insurance on the property and collection, health insurance. Paid advertising on reptile related websites. Paid advertising in reptile related magazines and publications. Travel expenses to attend the reptile shows across the country, fuel, flights, hotel rooms, food and drink, show expenses. Veterinarian, medication, record keeping and feeding expenses. Supplies and equipment paid for such as caging, bedding, heating and lighting, watering supplies and feeding. Employees who work a 40 hour-plus week insuring that the collection is well cared for and maintained are PAID. All of these expenses affect the flow of economics. A ban would cripple the millions of dollars that flow though the reptile industry each year.

Rodent suppliers. Snakes have to eat, and a ban would put most of the major rodent breeders in a situation where it would not be profitable enough to continue staying in business. “Snake food” is one of the biggest, if not THE biggest expense when keeping boas and pythons. The rodent industry, like that of the “snake breeders,” is very similar in expenses. Caging, bedding, feed, watering equipment, ventilation are all major expenses to a rodent company. Rodent breeders get their money to operate from people who keep and breed snakes. Rodents are supplied all across the United States to zoos and institutions, retail stores, hobbyists, enthusiasts and professional snake breeders.

Reptile related manufactures. This list could be a mile long, as there are literally thousands of reptile related products being manufactured, bought and sold. The market for “Reptile Stuff” is too huge to imagine. I owned a reptile shop in the nineties when the reptile craze was just getting started. The list of reptile products to order from was overwhelming. The reptile products are very specific in design. Development and manufacturing expenses are HUGE. Caging, heating and lighting are the back bone of retail shops when it comes to reptiles. I can only imagine how many small retail pet shops would go out of business due to the fact that they could not sell boas and pythons and all the equipment to go along with them. Some smaller “reptile only” shops would surely be out of business in one swift motion from a nationwide ban, along with the private snake breeders and rodent breeders.

Miscellaneous Suppliers. One would be very surprised to know that a lot of the supplies needed and purchased to keep snakes come from the general hardware stores local to the reptile keepers. Lowes, Home Depot, Wal-Mart, local hardware shops, paper supply companies, stationery companies, printer and graphics companies, nurseries and grocery stores.

Above are just a few of the things I can easily see being greatly affected by a ban. The examples listed are real. I am a very big part of the “boa and python” community and totally understand how each of the examples above will affect each other in the “snow-ball” affect if there were to be a ban. As a professional snake breeder of course I want to protect my best interests along with the thousands of others out there who love working with boas and pythons. I feel backed into a corner to have to defend what I love to do with examples that really shouldn’t even have to be discussed.

But they do need to be brought out and made public so that people can see and try to understand just how each affect the other. On a small scale this would be a drop in the bucket and a few businesses would feel a crunch. On a national level it would just collapse the reptile economy. Businesses would fail and people would lose jobs. It’s hard to believe that Burmese Pythons that already are loose in South Florida would be responsible for the “extinction” of boa and python trade across the US? I guess that would be a good one for The Discovery Channel. It could be titled “The extinction of boas and pythons in captivity in the United States, and the existence of Burmese Pythons in the Everglades.”

Burmese pythons in South Florida are just that. They are in South Florida. With that said, I can understand the need for action in South Florida. But NOT at a national level. I would hope that USF&WS would not even consider this ban and find a more logical solution at a local level. So please take into consideration just how badly a ban would affect the entire nationwide industry as a whole. An estimated 4.8 million US households own one or more pet reptiles. Boas and pythons are at least 25% of that, at the very least.

In response to the questions in the NOI, some have been commented on in the above.

1) Maryland has only one law that I know of. This is in Baltimore City and you can not keep a boa or python over five feet in length within city limits. You also can not release a boa or python into the wild. For the record, it would be dead by the winter.

2) I myself produce on average 500 babies annually (mostly ball pythons). I could only guess that 100,000 total for both boas and pythons combined in The US would be a fairly close estimate. There are some breeders in The US that produce several thousand boas and pythons each year. Every state where boas and pythons are legal has breeders producing boas and pythons.

3) Internet websites, magazine ads, vendors at reptile shows and forum participation would lead me to believe that 3000 to 5000 businesses sell boas and pythons. That is doing some of my “own math” taking into consideration how many states boas and pythons are being produced in.

4) I would have to say this answer is the same as the answer to question # 3. It could possibly be 25% lower than question # 3 as this question asks for the number of actual “breeders.” Not necessarily people in business to just sell, but people who produce babies from their boas and pythons each year.

5) MILLIONS, some of the wealthiest people I know are boa and python breeders or buyers of boas and pythons. They also funnel hundreds of thousands of dollars back into their business which in turn feeds other businesses.

6) In Maryland I have a license issued by the Humane Society Animal Control Division. The license is good for 12 months; my facility is inspected prior to renewing my license each year. The license allows an owner to operate as a commercial animal establishment.

At a National level the number of boas and pythons imported are regulated by CITES.

7) What the cost would be to eradicate in South Florida? I know of ZERO examples that I could reflect on as to estimate the cost of eradication. These boas and pythons will NEVER establish anywhere else other than the Everglades. The Everglades are the perfect climate that reptiles love. The Everglades are known for gators and snakes.

A ban would surely have thousands of people thinking more about “eradication,” and that is sad. What happens to an established breeding boa and python collection that have just become “pets” due to the ban? Sure you love them just the same, but how will you be able to earn the money to feed and care for them? Eradicate?

8) I would not know the answer to this question. The Everglades are HUGE and a lot of time has passed. I bet if we keep developing property and stealing valuable habitat that the Burmese will be affected just like the rest of the threatened and endangered. I would bet that if people were told that the Burmese will not EVER end up living and thriving in the Ohio Valley that they could accept the Burmese in the Glades along with the iguanas and skunk ape.

9) Boas and Pythons can NOT live or thrive in Maryland outside of captivity, therefore there is no way for any native species to be impacted by them. Of course if one were to escape it could possibly capture and eat a large rodent, rabbit, raccoon or opossum. A boa or python would surely be DEAD or dying at the first frost. Boas and pythons are extremely sensitive to cold temperatures. In my experience a boa or python can catch a respiratory illness (RI) at mild temps in the 70’s. This upper respiratory issue untreated will lead to the death of the snake. The snake will accumulate fluids in the lungs, trachea and nostrils and eventually suffocate to death on accumulated mucus. Upper respiratory disease is a leading cause of death in pythons especially. It is not uncommon for them to die within a couple days of showing symptoms if it is not treated. Burmese pythons are known to have RI issues and many breeders stopped keeping them for that reason.

It is very common in the winter months when breeders are breeding their boas and pythons to see questions asked on the forums or in emails about upper respiratory problems in their snakes. These questions are usually asked by novice keepers who have allowed their snakes to get too cold during the winter breeding season. 99% of these snakes will die if not treated with antibiotics. These snakes are being kept in-doors at mild temps and they still DIE.

The number one key to keeping boas and pythons successfully in captivity is knowing what their heat requirements are. One of the biggest product types in the industry is HEATING products. There are thermostats and rheostats, heat tape and heat mats, heat lamps, heat bulbs and temp guns. The best commercial snake cages / racks are out-fitted with heat panels under each snake tub to ensure that the snake get’s the correct “belly heat” to digest properly and stay healthy. Some breeders will even heat a room to a minimum of 80 degrees AND use the commercial heat sources to insure that the snakes have the correct heat requirements.

Boas and pythons can not thrive indoors without the right heat to digest and to keep a healthy respiratory system. It is impossible for them to live in the wild where temperatures become mild for long periods of time. Boas and pythons do not hibernate when they are cold, they DIE. South Florida is just one big HEAT MAT.

Boas and pythons that slither NORTH for the winter are DEAD SNAKES. They need heat and some humidity to thrive. Like I said previously, HEAT goes “hand in hand” with keeping boas and pythons. They are cold blooded and easily fall ill when kept cold even for short periods of time. I know of incidents where pythons have been shipped overnight and experienced flight delays. The inexperienced shipper did not factor in the possible delay (using heat packs and packing the snakes warm). The pythons were received “chilled” due to delay and immediately showed signs of RI.

I have witnessed Burmese in collections and been in a facility where you could see the mucus from sick Burmese all over the front glass of the enclosures and you could hear the snakes coughing and hacking up mucus. I have been told that the Burmese are too big to treat for RI and they lack the ability to exercise which helps break the mucus loose so that the snake can expel it. Pythons are extremely sensitive to mild temps.

In my years of experience with boas and pythons I have experienced first hand what upper respiratory disease does. It kills if untreated—PERIOD. Some breeders will not treat with antibiotics and instead try to warm the snake up at a warmer temp than usual to try to “cook it” out of them. This does seem to work as the snake will stop showing the symptoms of “wet mouth.” Wet mouth is the first symptom of RI. An experienced breeder will notice the snake has a wet fluid discharge around the gum-line. The snake may also crackle when it breaths due to congestion in the lungs. The snake will also try to elevate its head to breath due to congestion. The snake’s enclosure will become “slimy” because the snake is drooling due to it constantly having to keep its mouth open to breath. It will rub the drool from the sides of its jaw on everything that it can inside the cage. Getting back to the “cooking it out”. If a snake is not treated and shows signs of improvement, 9 times out of 10 it will relapse worse—the next time it is chilled it will die.

10) I know of one incident in my town that made the local news. A large Burmese Python had escaped from its cage in “farm country,” it found its way outside. A farmer was running a big combine in his fields taking down feed corn when the combine came to a screeching halt. It turns out that he ran over the poor lethargic Burmese in his field. I believe the farmer had to make some expensive repairs to his combine after the incident. The Burmese Python was shredded and killed instantly.

In conclusion, I would like to say that I appreciate what USF&WS does. I will be more than happy to help with any other inquiries. I do not know of any evidence that even remotely suggests a problem outside of South Florida.  I do not know how the listing of Injurious Wildlife could do anything to improve the issue in South Florida.

Sincerely,
Ralph Davis

 

 

 
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