PIJAC comments on USFWS NOI

For a copy of the comments that PIJAC submitted to the USFWS on the amphibian/Bd Notice of Inquiry, please visit the Breaking News page on PIJAC's website and scroll down to the December 17, 2010 entry:

PIJAC Submits Comments on U.S. Fish & Wildlife Service NOI Concerning Amphibians in Trade

http://www.pijac.org/petinformation/breakingnews.asp

PIJAC Launches Bd-Free 'Phibs Website

See the official release at: http://www.pijac.org/petinformation/press.asp

FOR IMMEDIATE RELEASE

1140 19^th Street, NW

Suite 300

Washington, DC 20036

Contact Jamie K. Reaser: 434-990-9494

21 September 2010

PIJAC LAUCHES BD-FREE ‘PHIBS WEBSITE

PIJAC is pleased to announce that it is launching the official website for its “Bd-Free ‘Phibs campaign” – http://www.bd-freephibs.com. The campaign was initiated in November 2007 at an international conference that PIJAC co-hosted on amphibian declines and the fungal pathogen Batrachochytrium dendrobatidis (or Bd for short).

“Amphibians are the most threatened group of animals worldwide,” says PIJAC’s Vice President for Environmental Policy and Communications, Dr. Jamie K. Reaser, who did her doctoral work at Stanford University on amphibian declines. “In recent decades, scientists have observed dramatic population declines and even extinctions of numerous amphibian species. Although habitat destruction is generally regarded as the primary cause of amphibian declines, numerous studies now attribute many of the die-offs to a newly recognized, fungal pathogen known as Batrachochytrium dendrobatidis (Bd).”

The disease caused by Bd, known as chytridiomycosis, is the worst infectious disease ever recorded among wildlife in terms of the number of species impacted and the severity of the impact.

Bd was initially detected in amphibians held in zoos for educational and conservation purposes. It has caused mortality in some collections and could put rare species (including those in captive propagation programs) at severe risk. There is increasing evidence that the commercial trade in amphibians for pet/hobby, food, biological supply, and bait purposes has resulted in the movement of Bd. Loss of Bd-infected amphibian in the commercial sector and within hobbyist collections could have a substantial economic impact.

The Bd-Free ‘Phibs campaign provides information for amphibian keepers on ways to help reduce the spread and impact of Bd on captive amphibian populations. It also strongly discourages the released of captive amphibians into the wild, where they could become invasive by infecting native amphibians with pathogens or parasites.

The new website provides an overview of the issue and campaign; information on how you can support the campaign; and links to resources for background information on Bd, as well as testing and treatment protocols. One of the most important and unique aspects of the website is a database ("Partners Forum) for sharing information on camp.aign-related projects. In the near future Bd-Free 'Phibs T-shirts and other materials will be available through an online store.

PIJAC strongly encourages amphibian keepers who are already engaged in Bd education, testing, and/or treatment to complete a profile on the Bd-Free ‘Phibs website’s Partners Forum page. In light of the recent Notice of Inquiry on amphibians and Bd released by the U.S. Fish and Wildlife Service (see the PetAlert on PIJAC’s Breaking News page; www.pijac.org), it is imperative that the pet industry demonstrate leadership and responsibility on this issue.

PIJAC thanks the Pet Care Trust and Reptiles Magazine for supporting the development of the campaign website. For further information, please see the Thank You page on the Bd-Free ‘Phibs website.

PIJAC membership is open to all segments of the pet industry, as well as individual pet owners. For information on how you can join, please contact Nancy Knutson, Director of Member Services, at members@pijac.org.

For more information on PIJAC, please visit: www.pijac.org.

-PIJAC-

PIJAC’s mission is to promote responsible pet ownership and animal welfare, foster environmental stewardship and ensure the availability of pets.

Pet Product News Article on Feds Mulling Trade Ban

On 21 September 2010, Pet Product News published the following article entitled, "Feds Mull Trade Ban of Amphibians to Control Chytrid Fungus."


http://www.petproductnews.com/headlines/2010/09/21/feds-mull-trade-ban-of-amphibians-to-control-chytrid-fungus.aspx

USFWS Publishes NOTICE OF INQUIRY

Note - For more information, please see our first blog post on this issue and download PIJAC's PetAlert at:

http://www.pijac.org/_documents/us_fws_amphibian_noi_2010.pdf

THE ISSUE

The Fish and Wildlife Service (FWS) has published a Notice of Inquiry seeking information on the importation and transportation of live amphibians or their eggs and Batrachochytrium dendrobatidis (chytrid fungus). The FWS Notice is a response to a Petition submitted by Defenders of Wildlife on September 9, 2009 to list “all live amphibians or their eggs in trade as injurious unless certified free of Batrachochytrium dendrobatidis (chytrid fungus).

The FWS Notice seeks information on the biological, economic or other trade data regarding the addition of live amphibians as injurious unless free of the fungus.

The service is soliciting information and supporting data from the pubic including information responding to the following questions:

1. What Federal, State, or tribal regulations exist to prevent the spread of chytrid fungus?

2. Are there any known mechanisms in the United States to test for, control, or regulate movement or interstates transport of chytrid fungus?

3. How many businesses import live animal amphibians or the eggs into the United States?

4. How many businesses sell live amphibians or their eggs for interstate commerce?

5. What are the annual sales of these imported live amphibians and their eggs?

6. What species of amphibians, fish, or other class of animal have been affected by chytrid fungus in the United States and were they infected?

7. What are the current and potential effects to species listed as threatened or endangered under the Endangered Species Act that are contaminated with chytrid fungus?

8. What are the potential costs of recovering threatened or endangered species affected by chytrid fungus?

9. What is the likelihood that wild amphibians would be affected by the importation of live amphibians or their eggs that harbor chytrid fungus?

10. What would it cost to eradicate chytrid fungus?

11. Are there any potential benefits to allowing the chytrid fungus pathogen to be imported?

12. What is the potential for the industries that conduct trade in amphibians to self-police through voluntary best practices; for example, how successful is the “Bd-Free Phibs Campaign” sponsored by the Pet Industry Joint Advisory Council? [Note from PIJAC – please see www.bd-freephibs.com. This website has just been launched by PIJAC. The program is open to anyone addressing Bd in the ex-situ (captive) context. We encourage you to fill out a partner profile]

13. What peer-reviewed methods for detecting chytrid fungus have been published?

14. Are there any other comments or information regarding the listing if live amphibians as injurious unless free of chytrid fungus?

THE IMPACT

What would be the impact if listed? Importation into the United States, export from the United States and interstate movement would be prohibited unless they are free of chytrid fungus. Every shipment would have to be accompanied by a written declaration prescribed by the FWS that “indicates the shipment meets or exceeds the recommendation [certification and handling system] of the World Health Organization for Animal Health in its Aquatic Animal Health Code on Batrachochytrium dendrobatidis.” The estimated cost to obtain the written declaration and associated shipment/transport clearance has not been provided by the FWS.

HOW TO RESPOND

Comments should be submitted by no later than December 16, 2010 by one of the following methods:

• Post via the internet http://www.regulations.gov. Follow the instructions for submitting comments to Docket No. FWS-R9-FHC-2009-0093.
• Mail or hand-delivery your comments: Public Comments Processing, Attn: Docket No. FWS-R9-FHC-2009-0093, Division of Policy and Directive Management, U.S Fish and Wildlife Service, 4401 North Fairfax Drive, Suite 222, Arlington, VA 22203.

Additional information may be obtained by contacting Susan Jewell, Branch of Aquatic Invasive Species, U.S. Fish and Wildlife Service, MS 770, 4401 North Fairfax drive, Arlington, VA 22203; telephone 703-358-2416.

PIJAC is working with other potentially affected stakeholder groups in addition to the pet industry to collect relevant data as well as establish means of communication and dialogue among interested PIJAC members. PIJAC will also set up listening sessions with technical experts.

PIJAC is also conducting a thorough analysis of the proposal and response.

PIJAC invites you to visit the Bd-free Phibs website to learn more about the issue and input a partner profile if you are a already engaged in testing and treatment, etc. If you are an amphibian keeper/hobbyist or business involved in the commercial trade in amphibians, visit the website to see how you can become better educated and involved.

Background

On September 9, 2009, Defenders of Wildlife filed two petitions - one with the Department of the Interior and the other with the Department of Agriculture – urging them to take immediate action to regulate live amphibian imports in the pet, food, scientific and live bait trades so as to minimize the spread and impact of an amphibian pathogen known as Batrachochytrium dendrobatidis, “Bd,” or "chytrid fungus."

For a copy of the petitions, see:

http://www.defenders.org/newsroom/press_releases_folder/2009/09_09_2009_as_deadly_fungus_spreads,_defenders_seeks_stronger_protections_for_native_amphibians.php

In response to the petition, the U.S. Fish and Wildlife Service (USFWS) is preparing a Notice of Inquiry (NOI) which will be published in the Federal Register and invite public comment - particularly with respect to regulating the importation and between state movement of non-native amphibians through the Lacey Act (http://www.fws.gov/le/pdffiles/lacey.pdf).


PIJAC recognizes the risks that Bd poses to both captive and wild amphibians worldwide. Over the last few years it has:

*Co-organized an international conference on Bd - http://www.parcplace.org/Bd_conference.html

*Launched the "Bd-free 'Phibs" campaign for amphibian hobbyists, zoos, and aquaria -
http://www.pijac.org/projects/project.asp?p=26

*Published an article on Bd and the campaign in Reptiles Magazine -
http://www.reptilechannel.com/reptile-magazines/reptiles-magazine/may-2008/under-fire.aspx

*Contributed to an article on Bd in PetAge Magazine - http://www.pijac.org/_documents/0509%20cover%20story.pdf

*Promoted the campaign in PIJAC's PetLetter - http://www.pijac.org/_documents/petletter_bdfreephibs.pdf

*Educated hobbyists and pet owners on the importance of rehoming, rather than releasing, unwanted pets through the Habitattitude campaign - http://www.pijac.org/projects/project.asp?p=27

Even though the NOI has not yet been released, PIJAC is strategically consulting with its Members and key partners on the most appropriate response. PIJAC has every intention of taking a position that is pro pets, pro responsible business, and pro environment.

Please use this blog - and the links to it - to learn more, and when the time comes...to take action.

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Frog photo in blog header - (c) Vincent Russo, Cutting Edge Herp Inc.