Some Like It Hot: Venomous Reptiles in Florida

Florida's FWC to update Venomous Reptile regulations

Florida’s FWC to update Venomous Reptile regulations

Venomous Reptiles and Rule Change
The State of Florida has a long and storied history with captive venomous reptiles going back almost a century with famed herpetologists Ross Allen and Bill Haast. But in the wake of two high profile venomous snake escapes, Florida Fish and Wildlife Conservation Commission (FWC) has come under increased political pressure to tighten up venomous reptile regulations in the name of “public safety.” A new proposed rule is in the works, and there will likely be significant changes in regulation for zoos, venom labs and private keepers alike. FWC is currently accepting input from stakeholders through an online survey at Deadline for the surveys is July 27, 2016. There is also an opportunity to make public comment directly to FWC.

FWC has created a venomous reptiles working group known as the Venomous Reptiles Technical Assistance Group (VRTAG) to solicit stake holder input as a part of the process of formulating a draft proposed rule. FWC has a history of using TAG groups when seeking subject matter expertise on a given issue. I was selected as a resource to the VRTAG by FWC to represent clients in the zoo sector on behalf of Vitello Consulting. VRTAG meetings were held in early June and again in early July. Although the working group meetings were well run and allowed for an open exchange of ideas, there were clear lines of disagreement between FWC staff and the majority of VRTAG members.

The biggest point of contention between VRTAG members and FWC staff centered on a proposed three tier system of classification for venomous reptiles, with Tier I reptiles being unavailable for possession by private keepers that don’t meet the definition of “commercial” — such as dealers, zoos or venom labs. There could also be an increase in documented hours and/or educational requirements for venomous reptile license applications. Focus would be on incrementally moving up the tier system over time like building blocks — i.e., with Tier III being a prerequisite for Tier II, and Tier II a prerequisite for Tier I. Additionally, a proposed rule would likely require secondary containment for all three tiers, with tertiary “lockout doors,” specially constructed “out buildings,” and “pit tag” identification for Tier I reptiles.

Public Comment
Aside from the online survey that is being conducted by FWC, it is imperative that anyone who has an interest in venomous reptiles in Florida to make a substantive public comment. This is not just an up or down vote. If you want your public comment to carry weight, you must submit “substantive” public comment. That is a comment that specifically addresses concerns about the current draft of the proposed rule, or suggests alternatives to provisions of the draft. Being generally for or against the draft rule will not carry much weight.

Make Public Comment to FWC regarding Venomous Reptiles and the VRTAG!

Please make public comments here:

Below are all of the current documents forming the basis for a draft proposed rule. Provisions of the draft rule will likely change at least somewhat. I should have an updated draft sometime in September. I will post an update as soon as possible.

Andrew Wyatt is a government affairs and policy consultant that works exclusively in the wildlife sector.

WyattP1“Venomous Reptiles and other wildlife issues are highly charged and contentious. I specialize in working with clients to employ campaign style tactics to change hearts and minds on vital wildlife issues. Please follow The Last Word on Wildlife for insight and analysis particular to the 21st century wildlife sector. If you would like to discuss the potential advantages of running a targeted issue campaign, and/or a comprehensive government affairs strategy, please call or email me.” ~ Andrew Wyatt

© Andrew Wyatt and The Last Word on Wildlife, 2016. Unauthorized use and/or duplication of this material without express and written permission from this blog’s author and/or owner is strictly prohibited. Excerpts and links may be used, provided that full and clear credit is given to Andrew Wyatt and The Last Word on Wildlife with appropriate and specific direction to the original content.

Angry Tweets Won’t Help African Lions

“… hunting was never really the main problem.” ~ Richard Conniff for The New York Times

strange behaviors

ZWE_BWA_120928_1701_04284_F-Blog (Photo: Craig Taylor/Panthera)

by Richard Conniff/The New York Times

THE killing of Zimbabwe’s celebrated Cecil the Lion by a Minnesota dentist, on July 1 of last year unleashed a storm of moral fulmination against trophy hunting. People for the Ethical Treatment of Animals issued an official statement calling for the hunter, Walter J. Palmer, to be hanged, and an odd bedfellow, Newt Gingrich, tweeted that Dr. Palmer and the entire team involved in the killing of Cecil should go to jail. The television personality Sharon Osbourne thought merely losing “his home, his practice and his money” would do, adding, “He has already lost his soul.”

More than one million people signed a petition demanding “justice for Cecil,” and three major American airlines announced that they would no longer transport hunting trophies. A few months later, the United States Fish and Wildlife Service listed lions from West and Central…

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Fossil Rim factors into scimitar-horned oryx reintroduction

“Fossil Rim embodies the spirit of captive conservation.”– Andrew Wyatt

Words On Wildlife

On the other side of the world, animals that have been extinct in the wild since 2000 are mere months away from roaming freely in their native land once again.

The first 25 of 500 scimitar-horned oryx set for reintroduction into Chad arrived in the country March 14. The project’s driving force is the Environmental Agency – Abu Dhabi (EAD).

With the green light, participants at 17 locations across America, Europe and the United Arab Emirates (UAE) were able to begin shipping oryx to Abu Dhabi, the UAE capital, with the goal of building a “world herd.” From there, the first 25 were sent to Chad.

SHO exit crates A couple of the first 25 scimitar-horned oryx from the “world herd” hit the ground running in Chad after being transported from Abu Dhabi. Currently in a fenced area, they are slated for release into the wild August 21. Thus far, Fossil Rim Wildlife…

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When Animal Rights Sabotage the Natural World

“It is becoming more and more apparent that HSUS has little understanding of the natural world, and even less understanding of conservation and wildlife management.”– Andrew Wyatt

strange behaviors

Deer-herd-web-2-26-06My latest for

There are times—too many times, in truth—when understanding and protecting the natural world demands that we band together to stop the killing: The macho practice of shooting wolves in the American West comes to mind as an example. So does the relentless slaughter of elephants and rhinos in Africa. But at other times, protecting the natural world requires us to kill, and this is the painful reality some animal rights activists refuse to understand.

It’s not a failure to communicate. Animal rights groups are often brilliant at communicating. It’s a failure to reason in the face of scientific evidence, and it comes up almost endlessly for people who do the real work of protecting the natural world.

The latest case happened in Ann Arbor, Michigan. The city wanted to cull a booming deer population that is destroying the forest understory, damaging local landscaping, and…

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White Tiger: The Color of Controversy

“An interesting reassessment of white tiger genetics and the politics surrounding the issue.” — Andrew Wyatt

Tiger Tales

Royal White Bengal Tiger ~ ©Rare Species Fund Royal White Bengal Tiger ©Rare Species Fund

White Tigers are NOT Genetically Defective
There is no evidence of a genetic defect inherent in the white color variant of the Royal White Bengal Tiger, notwithstanding the erroneous claims to the contrary by the Humane Society of the United States (HSUS) and the Association of Zoos and Aquariums (AZA). White tigers have a normally occurring, simple recessive genetic color variant known as leucism, much the same as the leucistic (white) deer common to the Carolinas. Leucism and albinism are not the same. White tigers are not albinos and do not carry the genetic weaknesses associated with albinism. According to a recent study published in Current Biology, the gene, known as SLC45A2, is a naturally expressed color variant that was common in wild tiger populations prior to extirpation by poachers, hunters and habitat fragmentation in the 1950’s.

White Bengals result from genetic mutations that are part…

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Burmese Python: Dragon of the Everglades


South Florida Burmese Python

The 2016 Python Challenge™ is moving at a record pace in south Florida. Sponsored by the Florida Fish and Wildlife Conservation Commission (FWC), the controversial python hunt, ostensibly to remove invasive snakes from the Everglades, produced a disappointing tally of only 68 snakes after 30 days of hunting in 2013. With cooler temperatures in south Florida, 100 pythons have already been taken in 2016. Hunters have capitalized on greater snake visibility as pythons bask openly in the sun to retain warmth. But is the hunt, slated to finish on Valentines Day, really for conservation or just a publicity stunt?

Raising the specter of giant pythons in the Everglades has become a media pastime in Florida. Clearly the appetite for this farfetched story is not easily sated. Lauded as some kind of invasive dragon devouring endangered wildlife and family pets alike, the Burmese python has become the stuff of folklore and myth: a modern day Jaws. A myth promulgated by environmental groups, invasion biologists and the press. Pythons being slain by champions eager to battle dark denizens for the ecological life of the Everglades has become a symbolic narrative that politicians have adopted and regurgitated for their own political purposes.

There is no denying that there are tens of thousands of Burmese pythons in the Everglades, but that’s far fewer than the 100’s of thousands touted by the likes of U.S. Senator Bill Nelson or Dan Ashe of the U.S. Fish and Wildlife Service. While pythons are certainly eating rabbits, rats, feral cats and an occasional small gator, what many people don’t realize, is that pythons don’t eat every day like a warm blooded predator. They may only eat a handful of times per year; hardly the “resource hogs” depicted by some biologists.

“Cold temperatures killed thousands of pythons in the Winter of 2009-2010. Numbers appear to be rebounding, but pythons are not being found as readily as they were. The population peaked in Summer of 2009 with highs estimated to be 30,000- 40,000 pythons.” — Shawn Heflick, Biologist and star of NatGeo WILD’s: The Python Hunters

Another part and parcel of the myth is the notion that pythons have no natural predators in the glades. Nothing to temper an unabated population growth, a notion that is patently false. Any biologist worth his salt can tell you, there are dozens of potential predators for pythons in south Florida. Baby pythons are extremely vulnerable to hawks and eagles, wading birds, predatory fish, raccoons, feral hogs, feral cats, not to mention the apex predator of the Everglades, the American alligator, which preys even on adult pythons.

The exaggeration of every detail surrounding the presence of pythons in the glades further clouds the facts. For a variety of reasons the press and the pundits seem invested in demonizing the python. The press loves the idea of a giant snake in the glades “eating everything in its path.” Clearly the public has a morbid fascination with snakes that kindles a primal fear. Environmentalists and agency personnel see opportunity to increase funding for invasive, and or endangered species research not stimulated by less sensational problems. Ambitious biologists seem to bank on decades of pythons study and research in their future. Politicians vilify the snake as a threat that can only be overcome with the appropriation of billions in Everglades restoration dollars. It is a rich issue with a handout for nearly everyone.

“… many are content to chase the ‘Burmese Dragon’ around south Florida like Don Quixote chasing windmills.” — Andrew Wyatt

But the reality is this: Burmese pythons are a relatively low rung on the ladder of serious problems facing the Everglades. They have become a red herring, a distraction, and a scapegoat from more fundamental problems that are either too contentious or too difficult to deal with. Instead of addressing issues surrounding big sugar, pollution, water flow or other more pervasive invasive species threats, many are content to chase the ‘Burmese Dragon’ around south Florida like Don Quixote chasing windmills.

Hunting invasive pythons, although not without merit, is not being pursued in earnest. The National Park Service (NPS) will not allow pythons to be hunted at the epicenter of the population in the Everglades National Park (ENP). Ironically, the NPS appears to be protecting those pythons in order to preserve a study group for ongoing research. For the hunts to be effective, they should be conducted in the ENP in an open and ongoing basis. For now, hunts are restricted to state lands around the periphery of the park, and are limited to 30 days every few years.

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Vendors selling snakeskin wallets and belts at the 2016 Python Challenge™

The actual 2016 Python Challenge™ takes on an air more commensurate with a rattlesnake round-up or a reality TV show, than an environmental clean-up. It attracts colorful characters from all over the country to ‘hunt’ the dreaded pythons. Vendors have booths and sell t-shirts, snakeskin wallets and belt buckles. There’s funnel cake and BBQ. FWC is omni-present “educating” the public about the dangers of large pythons, how to identify them, wrangle them, and how to report them. But one has to wonder if the purpose is conservation or carnival.

While some concerns regarding invasive pythons are legitimate, the dramatic characterization placing pythons at the center of all of the Everglades ecological troubles is way overblown. Efforts to reduce the population via the Python Challenge are ineffective and disingenuous. Python population will never be significantly reduced unless the hunt is conducted at the epicenter of the invasion in the heart of the ENP. Allowing an open season within the park is the only way to actually reduce numbers through hunting. This ‘Dragon’ hunt  can hardly be seen as anything but a side show, while the decline of the Everglades goes on with or without the Burmese python circus.

Andrew Wyatt is a government affairs and policy consultant working exclusively in the wildlife sector. He formerly served as the CEO of the United States Association of Reptile Keepers (USARK) where he twice testified before congress as an expert on python issues. Andrew has been interviewed on National Public Radio, by Bloomberg and by The New York Times.

FWS Lists 201 Salamanders as Injurious

Captive Bred Chinese Fire-bellied Newt

Captive Bred Chinese Fire-bellied Newt

Utilizing the recently enacted Categorical Exclusion, or CatX, the U.S. Fish and Wildlife Service will short-cut procedural checks and balances previously mandated under the National Environmental Policy Act (NEPA). Tomorrow FWS will publish an interim rule in the Federal Register adding 201 salamander species to the “Injurious Wildlife” list. The rule will be enacted without the necessity of FWS to submit an Environmental Assessment (EA), or an Environmental Impact Statement (EIS) under NEPA.

The new rule adding many salamanders to the Injurious list will be enacted as of January 28, 2016, and would have been logistically impossible without the enactment of CatX late last year. After January 28th, import or interstate transport of listed salamanders, without a rigorous federal permit, will be prohibited.

Why is FWS listing Salamanders as Injurious?

To help prevent a deadly fungus from killing native salamanders, the U.S. Fish and Wildlife Service is publishing an interim rule tomorrow to list 201 salamander species as injurious wildlife under the Lacey Act. The fungus Batrachochytrium salamandrivorans, also known as Bsal or salamander chytrid, is carried on the skin of various salamander species. Bsal has caused major die-offs of salamanders in Europe and poses an imminent threat to U.S. native salamander populations. — U.S. Fish and Wildlife Service

While justification for the unprecedented move is not without merit, it bears noting that Bsal has never been found in the U.S., and there has been no evidence of a connection between the spread of Bsal and herpetoculture; the captive production of reptiles and amphibians. Last year, Zoos and the pet industry voluntarily agreed to suspend imports of salamanders into the U.S., increasing speculation regarding FWS’ motivations for the listing. Some will certainly conclude that this move is less about stopping Bsal, and  more about establishing CatX in the law for more liberal future use.

Impact to Herpetoculture
Herpetoculturists will no longer be able to import listed species into the U.S., nor will they be allowed to conduct interstate commerce with captive bred specimens. Regulatory hurdles were put in place for a reason, to avoid arbitrary decision making by agency personnel, and to protect American citizens, business owners and organizations from being run over by their own government. This salamander listing appears to be more about testing the waters for future application of CatX, than stopping Bsal. CatX sets a poor precedent for process and fairness in the regulatory environment. Now that it has been established in the law, stakeholders may be dealing with the consequences of CatX for years to come.

Andrew Wyatt is a government affairs and policy consultant that works exclusively in the wildlife sector. 

WyattP2“The Lacey Act and other wildlife issues are highly charged and contentious. I specialize in working with clients to employ campaign style tactics to change hearts and minds on vital issues in the wildlife sector. Please follow The Last Word for insight and analysis particular to the 21st century wildlife sector. If you would like to discuss the potential advantages of running a targeted issue campaign, and/or a comprehensive government affairs strategy, please call or email me.” ~ Andrew Wyatt

© Andrew Wyatt and The Last Word, 2016. Unauthorized use and/or duplication of this material without express and written permission from this blog’s author and/or owner is strictly prohibited. Excerpts and links may be used, provided that full and clear credit is given to Andrew Wyatt and The Last Word with appropriate and specific direction to the original content.