**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]{.underline} 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