To Whom It May Concern,

My name is Ed Triplett, and 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 January 31, 2008. Reports of a breeding population of large
non-native snakes in southern Florida concerned me greatly, though I
believe regulations recently implemented by the Florida Wildlife
Commission to address \'reptiles of concern' will resolve any problems
they may cause. In any case, an 'Injurious Wildlife' listing would do
little to improve the situation there, as much of the interstate reptile
industry is based in Florida; such a listing may actually lead to an
increase in the number of captive reptiles released into the wild in the
one place in the U.S. that could conceivably support them, as small
businesses dispose of their stock illegally once legal avenues are
closed to them. Regarding the wider issue of large snakes in the U.S., a
thorough review of the available scientific literature has led me to
conclude that snakes of the *Boa*, *Python*, and *Eunectes* genera do
not pose a threat to the interests of agriculture, horticulture, or
forestry, nor to the health and welfare of human beings or welfare and
survival of wildlife and wildlife resources in the United States.

I am a trained biologist currently pursuing a PhD at Duke University.
Previously I worked at a responsibly managed private zoo in Myrtle
Beach, SC, which like almost all such organizations has never released
animals into the wild for any reason. I also worked for several years at
Lake Waccamaw State Park in the middle of the Green Swamp, a unique
ecological region home to endangered and threatened plants and wildlife
such as the Venus Flytrap, which grows wild in no other place on Earth.
I am devoted to my pets, but I am more committed to the protection of
this special place, and would do away with all of them if I believed
they were even a potential threat to the environment. The Green Swamp is
the habitat most conducive to the survival of large reptile species in
North Carolina, being the southernmost continuous natural area in the
state, and houses our state\'s largest population of American
Alligators. In the years I have worked, camped, and hunted in and around
the Green Swamp, I have never encountered or even heard of a snake of
the *Boa*, *Python*, or *Eunectes* genera surviving in the wild here,
nor in any other part of my state. Currently, there is no evidence to
suggest such an event anywhere in the country outside of south Florida,
which has a climate unlike that of the rest of America.

Snakes of the *Boa*, *Python*, or *Eunectes* genera are unlikely to ever
survive or establish a breeding population in the wild in the United
States, outside of southern Florida, due to simple facts of biology.
They are all ectotherms, requiring an external source of body heat to
maintain physiological and cellular processes. Large snakes, such as
*Boa*, *Python*, or *Eunectes*, require particularly constant warm
temperatures to digest their large meals. Freezing weather kills them,
meaning that the handful of animals released by irresponsible pet
keepers every year die by late fall, before they can have an impact on
the local ecosystem. None of these large snakes evolved to survive in
climates as cool as those prevailing in the continental United States.
The lone exceptions, the Rosy and Rubber Boas, are harmless natives to
the American Southwest that have never managed to extend their range
within the U.S., despite their being the species best adapted for doing
so.

I am also a member of the North Carolina Association of Reptile Keepers.
I have over fifteen years of experience in keeping pet snakes and other
reptiles, which I have used in award-winning demonstrations and
presentations for 4-H and other youth groups, classrooms, senior
centers, church groups, and museums. I have been able to advise others
on how to ensure their pets do not escape and furthered awareness of
alternatives to releasing unwanted pets into the wild, including
adoption programs as well as sanctuaries for the largest pythons and
boas. Half the reptiles in my collection are adopted pets, while the
other half were obtained through the interstate reptile industry. In the
rare case that a new home cannot be found or the local sanctuaries are
too full, I would always support euthanasia before release of a pet
animal into the wild - not because I believe release would endanger the
local population or ecosystem, but because release is simply a lazy form
of euthanasia that extends the animals\' suffering while casting the
herpetocultural community in unfavorable light.

In response to the specific questions raised in the Notice of Inquiry:

1\) I am unaware of any regulations in my state pertaining specifically
to the use, transport, or production of *Python, Boa* and *Eunectes*
genera, other than those that govern general animal welfare and the
captive possession of non-native species - which already prohibit the
release of such animals. The North Carolina legislature recently
considered additional regulation (SB1477) that would have limited the
captive possession of particularly large snake species to educational
purposes approved by permit, but a fact-finding committee determined
this regulation to be unnecessary to protect human health or other
interests.

2\) I have personally encountered over twenty species in the *Python,
Boa* and *Eunectes* genera produced for retail sale in North Carolina,
though this list is not exhaustive and I am only connected to this
industry as a consumer.

3,4,5) I am unaware of the exact number of businesses that breed or sell
*Python, Boa* and *Eunectes* species, though I know it to be at least in
the low hundreds. Every pet store I have ever visited, excepting one
national franchise, sells snakes from these species. I personally spend
\$100-\$300 annually on food, bedding, habitat, and medical care for my
pet pythons, though I am probably one of the thriftier python owners. If
the FWS can accept future comments, I will try to answer these questions
at the next semiannual NC Reptile and Exotic Animal Show, scheduled for
this weekend. Twice a year hundreds of small businesses transport
thousands of *Python, Boa* and *Eunectes* animals across dozens of state
borders to participate in this one event, yet there is no population of
non-native reptiles breeding in the wild as a result of this large-scale
interstate traffic. Large, popular events like this every weekend around
the country draw participants from around this and neighboring states,
and are a major source of revenue for the national pet reptile industry,
as well as boosting local service industries and fuel sales. Such events
have taken place for decades without any ill effects on human or
environmental health, demonstrating how little threat is posed by the
keeping and interstate transport of *Python, Boa* and *Eunectes*
species.

6\) This state has no upper limit on the number of species allowed.

7,8,9) There would be no cost to eradicate *Python, Boa* or *Eunectes*
species or populations, in the unlikely event they were found in NC, due
to the climate issue mentioned above. North Carolina includes the
northernmost range of the American Alligator (America\'s largest
reptile), which grows smaller here than anywhere else in its range, due
to the cold winters and relatively short summers found here. The
adaptations that allow the alligator to survive in the temperate United
States also limit its distribution in warmer climes, which is why it is
only found in the U.S. Similarly, the adaptations that allow *Python,
Boa* and *Eunectes* species to survive in their tropical climates
preclude their ever colonizing North Carolina, or anywhere else north of
the Florida peninsula. Their bodies have evolved with constant warm
temperatures that allow them to digest food, grow, and survive winter
without the physical and behavioral adaptations required of alligators.
Freezing weather kills them, so any individuals or populations found in
NC would expire naturally with the coming of winter.

10\) No wild species has been impacted in North Carolina by *Python,
Boa* or *Eunectes* animals.

I would like to thank you for reading my comments, and hope they have
been helpful.