NANFA-L-- new reptile regulations
Thu, 21 Apr 2005 18:19:17 -0500

Dear Mr. Conti:

I want to thank you and the Pennsylvania Fish and Boat Commission for
proposing regulations to increase the protection of native reptiles,
particularly those proposals that will help you to control the
undesirable transfer of non-native morphs into Pennsylvania and so
prevent their release into the wild. The genetic makeups of native
populations of animals and plants are under threat from indiscriminate
movements by individuals and tradespersons. Most individuals are
usually unaware, and education generally helps in such cases, but
tradespersons often do know what they are doing.

Some persons have suggested to me that, as they read your proposals,
some of the changes you are considering may not be based on sound
science. While I am sure that your personnel have made every effort to
develop regulations that reflect the knowledge we have, please do
review all proposals in light of demonstrated scientific findings.
However, that said, I recommend application of the precautionary
principle where conservation is concerned. That is, if an action is
not known to be beneficial to wildlife, and has potential for harm,
then it is probably undesirable and should not be allowed.

I understand that you have proposed to forbid citizens from having in
their possession in the field certain implements commonly used in the
censusing, handling, and collecting of reptiles, such as hooks and
tongs, except during a defined open season for rattlesnakes. Are there
legitimate uses for these implements outside the open season? Would
allowing possession of these implements make enforcement of collecting
or disturbing regulations difficult or impossible? Finally, I presume
that a scientist, with proper permits for his or her experimentation or
collecting, would be exempt from such a regulation. If the answers to
the questions I posed are (1) yes, and (2) no, then perhaps this
particular component of the proposal could be reconsidered.

Thank you again for making efforts for conservation of native wildlife.

David L. McNeely, Ph.D., Professor of Biology
Langston University; P.O. Box 1500
Langston, OK 73050; email:
telephone: (405) 466-6025; fax: 405) 466-3307
home page

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