**Dustin D. Rhoads**

983 South 600 West Provo, Utah 84601 USA 832-287-9207 subocs@gmail.com

30 April 2008

**To whom it may concern:**

I am writing in response to the Notice of Inquiry entitled, "Injurious
Wildlife Species; Review of Information Concerning Constrictor Snakes
from Python, Boa, and Eunectes genera," dated 31 January 2008, in the
Federal Register.

In introduction: I have 22 years of varied experience in herpetology and
in

herpetoculture, including the field of veterinary medicine for captive
reptiles and amphibians. In early 2008, I authored the first-ever book
on the Trans-Pecos Ratsnake (*Bogertophis subocularis*), a native
species of Texas, New Mexico, and the Chihuahuan Desert in northern
Mexico. The book is called *The Complete Suboc: A Comprehensive Guide to
the Natural History, Care, and Breeding of the Trans-Pecos Ratsnake*,
and it was published by ECO Publishing and released as the fourth and
newest book in their well-reviewed "Complete series".

I am a student at Brigham Young University (BYU) in Provo, Utah and am
now finishing a degree in Integrative Biology with emphasis in
herpetology. I have worked as a curatorial assistant at the Monte L.
Bean Life Science Museum at BYU and have worked as a veterinary
technician and veterinary assistant at exotic animal hospitals in
Houston, Texas.

I here submit the following comments in answer to some of the questions
posed in the Notice of

Inquiry:

**(3) How many businesses sell *Python*, *Boa* or *Eunectes* species?**

Many thousands. Nearly all U.S. pet stores have been selling *Python
regius* and *Boa constrictor imperator* for the past 30-40 years.
They're both a very common pet snake. In the *2001 American Veterinary
Medical Association Pet Ownership and Demographics Sourcebook* (AVMA),
the AVMA estimates that in 2001, the last year for which data is
available, that [616,000 snakes]{.underline} of all types were kept in
approximately [315,000 households]{.underline} in the United States.
Most of those snakes are kept as family pets (one or two animals), and
the majority of the species sold in pet stores are *Python regius* (Ball
pythons)*, Boa constrictor imperator (*red-tailed boas)*, Elaphe guttata
(*Corn snakes*), Lampropeltis spp. (*kingsnakes and milksnakes*),* and
*Thamnophis spp.(*garter snakes*)*. The first two mentioned here are in
two of these three genera.

**(4) How many businesses breed *Python*, *Boa* or *Eunectes* species?**

Easily thousands. (see Kingsnake.com's breeder business registry). Like
most snake species, they're low-maintenance, quiet, relatively odor-free
(when compared to keeping even a tiny fraction of the same number of
dogs, cats, birds, rabbits, ferrets, etc.), and hundreds of most species
in these genera can be kept safely and humanely in a bedroom-sized
Reptile Breeding Facility (RBF).

**(7) What would it cost to eradicate *Python*, *Boa* or *Eunectes*
individuals or**

**populations, or similar species, if found?**

Since the climate of Utah would not allow any populations of any of
these snakes to establish here, only the rare individual (possible
escapee or "releasee" of extreme animal rights activists, whose members
*have* been found guilty and charged with stealing and releasing the
livestock property of others, ***unlike*** citizen snake keepers, I
might add) would ever be found, that is, if it survived the dry, cold,
environment long-enough to be found alive. The aridity of the region
would, alone, cause severe upper respiratory infections in any of these
snake species. So for cost, one shot from a gun would "eradicate" an
individual snake. Or if captured humanely, the snake could be euthanized
at a veterinary hospital for under \$40.

**(9) What State-listed species would be impacted by the introduction of
*Python*, *Boa***

**or *Eunectes* species?**

In Utah - none. There are no feral populations in Utah of any of the
aforementioned genera, and the excessively dry, cold, Great Basin Desert
climate of the state would not support the ecological needs of any snake
species in those three genera. In short, one cold night in the 40s
Fahrenheit would kill all of the tropics-loving, equatorial snake
species of *Python, Boa, and Eunectes*. Since the severe winters here,
along with the fall and spring, are consistently below those
temperatures, none of those snakes could survive in Utah. There are even
more temperate-climate North American genera of snakes, such as
*Drymarchon* (Indigo Snakes) and *Drymobius* (Speckled Racers) that
could withstand colder temperatures than any pythons or boas, but yet,
could not adapt to the cold environment of Utah. (You may remember the
2002 Winter Olympics was held in Salt Lake City.)

**(10) What species have been impacted, and how, by *Python*, *Boa* or
*Eunectes***

**species?**

In Utah -- none. As far as is known, extreme southern Florida is the
only state to have any of these species established in populations.

Thank you for reading this. I sincerely hope that the scientific-minded
members of the USFWS will make an evaluation based on pure research. I
will continue to follow this process and engage in it as necessary.

Sincerely,

Dustin Rhoads