WWW.IRCF.ORG/REPTILESANDAMPHIBIANSJOURNALTABLE OF CONTENTS IRCF IRCF& AMPHIBIANS REPTILES • VOL &15, AMPHIBIANS NO 4 • DEC 2008 • 19(1):48–54189 • MARCH 2012

IRCF REPTILES & AMPHIBIANS CONSERVATION AND NATURAL HISTORY

TABLE OF CONTENTS COMMENTARY FEATURE ARTICLES . Chasing Bullsnakes (Pituophis catenifer sayi) in Wisconsin: On the Road to Understanding the Ecology and Conservation of the Midwest’s Giant Serpent ...... Joshua M. Kapfer 190 Constrictors,. The Shared History of Treeboas (Corallus Injurious grenadensis) and Humans on Grenada: Wildlife Listings, A Hypothetical Excursion ...... Robert W.1 Henderson 198 RESEARCH ARTICLESand the Industry . The Texas Horned Lizard in Central and Western Texas ...... Emily Henry, Jason Brewer, Krista Mougey, and Gad Perry 204 . The Knight Anole (Anolis equestris) in FloridaAriel H. Collis and Robert N. Fenili ...... Brian J. Camposano, Kenneth L. Krysko, Kevin M. Enge, Ellen M. Donlan, and Michael Granatosky 212 Georgetown Economic Services, LLC, Washington, D.C. CONSERVATION ALERT . World’s Mammals in Crisis ...... 220 n 2006, the South. MoreFlorida Than Mammals Water ...... Management District that the overall organism risk potential 223 ranged from medium Ipetitioned the U.S.. TheFish “Dow and Jones WildlifeIndex” of Biodiversity Service ...... (“Service”) (Reticulated Python, Green , 225 DeSchauensee’s 4 for federal assistanceHUSBANDRY in controlling the population of Burmese Anaconda, and Beni Anaconda ) to high (Burmese Python, 2 3 Pythons (Python bivittatus. Captive Care) ofin the Florida Central Netted. InDragon response, ...... the Northern African Python, Shannon Southern Plummer 226 African Python, Boa Service and the National Park Service requested that the U.S. Constrictor, and Yellow Anaconda5).6 In 2010, the Service Geological Service PROFILEconduct a risk assessment of nine constric- proposed a rule to list the nine as injurious wildlife . Kraig Adler: A Lifetime Promoting Herpetology ...... Michael L. Treglia 234 tor (“nine snakes”). In 2009, the USGS reported under the Lacey Act.7 Species listed as injurious wildlife COMMENTARY by the Service cannot be imported or transported between . The Turtles Have Been Watching Me ...... states lines. They can be exported Eric Gangloff but 238 only if the owner lives BOOK REVIEW within a state with a designated port and only after the owner . Threatened Amphibians of the World edited by S.N. Stuart, M. Hoffmann,acquires J.S. the Chanson, appropriate N.A. Cox, permits from the Service.8 When the R. Berridge, P. Ramani, and B.E. Young ...... Service proposed the rule to Robert list Powell the 243nine snakes as injurious

 CONSERVATION RESEARCH REPORTS: Summaries of Publishedwildlife, Conservation the Research Brown Reports Tree ...... Snake (Boiga 245 irregularis) was the  NATURAL HISTORY RESEARCH REPORTS: Summaries of Publishedonly reptile Reports on on Natural the History list...... 247  NEWBRIEFS ...... 248  EDITORIAL INFORMATION ...... In response to the proposed rule, 251 reptile industry par-  FOCUS ON CONSERVATION: A Project You Can Support ...... ticipants claimed that the nine-snake 252 listing would result in a

1 Opinions expressed in commentaries do not necessarily reflect those of the IRCF Front Cover. Shannon Plummer. or theBack editors Cover. of MichaelReptiles Kern& Amphibians. 2 Totat et velleseque audant mo SomeTotat authorities et velleseque continue audant mo to recognize the Burmese Python as a subspecies of the estibus inveliquo velique rerchil Indianestibus inveliquoPython (i.e., velique Python rerchil molurus bivittatus). erspienimus, quos accullabo. Ilibus erspienimus,3 See: Letter quos from accullabo. Kevin Ilibus McCarty, Governing Board Chairman of the South aut dolor apicto invere pe dolum autFlorida dolor apictoWater invere Management pe dolum District, to H. Dale Hall, Director of the U.S. Fish fugiatis maionsequat eumque andfugiatis Wildlife maionsequat Service, eumque23 June 2006. moditia erere nonsedis ma sectiatur moditia erere nonsedis ma sectia- 4 Python reticulatus, murinus, E. deschauenseei, and E. beniensis, respectively. ma derrovitae voluptam, as quos tur ma derrovitae voluptam, as 5 accullabo. Python bivittatus, P. sebae, P. natalensis, Boa constrictor, and Eunectes notaeus, respectively. 6 The organism risk potential is a measure of the probability that these snakes will breed, spread, and do environmental damage. R.N. Reed and G.H. Rodda. 2009. Giant Constrictors: Biological and Management Profiles and an Establishment Risk Assessment for Nine Large Species of Pythons, , and the Boa Constrictor. U.S. Geological Survey, Reston, Virginia, p. 7. 7 The Lacey Act, enacted into law in 1900, prohibits the purchase, transport, and trade of wildlife taken in violation of any law of the United States or any foreign country. The Act also prohibits the import and interstate transport of any species determined by the Service to be ecologically harmful. Listing reptiles as injurious wildlife is unusual. 8 Specifically, the Service stated that: “If the proposed rule is made final, live snakes, gametes, or hybrids of the nine species or their viable eggs could be imported only by permit for scientific, medical, educational, or zoological purposes, or without Both the Northern (Python sebae, top) and Southern African Rock Pythons a permit by Federal agencies solely for their own use. The proposed rule, if made (P. natalensis, bottom) are included in the four species listed on 17 January final, would also prohibit any interstate transportation of live snakes, gametes, 2012 as injurious wildlife. Photographs by L. Oberhofer (National Park viable eggs, or hybrids of the nine species currently held in the United States.” 75 Service) and L. Kroone. FR 11808, 12 March 2010.

Copyright © 2012. Ariel H. Collis. All rights reserved. 48 COLLIS AND FENILI IRCF REPTILES & AMPHIBIANS • 19(1):48–54 • MARCH 2012 significant negative economic impact on the reptile industry.9 a survey of industry members, publicly available information, In this paper, we address the economic impact of the Service’s and conversations with various reptile businesses and breed- proposal to list nine snakes as injurious wildlife. We also esti- ers, we estimate that reptile businesses collectively generated mate the impact of a compromise rule to list only four of the revenues of $1–1.4 billion in 2009. Table 1 provides lower- nine snakes as injurious wildlife. and upper-bound estimates of revenues realized in 2009 by various types of reptile businesses in the United States. Table Overview of the U.S. Reptile Industry 1 also shows that medical costs account for the largest share of Despite the fact that nearly five million U.S. households reptile industry revenues and that retailers (including internet owned close to 14 million reptiles as pets, and reptile busi- retailers) account for the second largest share. nesses earned revenues exceeding $1.0 billion from the sale, care, and housing of reptiles, the reptile industry has been Listing Nine Snakes studied little10. As a consequence, the imposition of federal Based on our review of the industry, we estimate that a limita- rules and regulations that directly affect this industry, such tion on sales of the nine snakes — the intended effect of such as the Lacey Act rule change, have been made without the an injurious wildlife listing — would result in lower industry information necessary to assess the economic impacts of revenues on the order of $76–104 million per year. Reptile these rules on the participants that comprise the U.S. reptile businesses with a higher proportion of their sales involving the industry. We were commissioned by the U.S. Association of nine snakes will bear the brunt of the lower revenues. These Reptile Keepers to provide a profile of the industry. Based on revenue losses would continue into the indefinite future. Ten years after enactment of the rule, present discounted revenue Table 1. Revenues of the U.S. reptile industry in 2009 by type of losses are estimated to run between $500 million and $1.2 business. billion, assuming historical industry sales growth. Imports.—If listed, all imports of the nine constrictor spe- Estimated Revenues (Million $) cies would be banned. Therefore, current and future revenues Business Type Lower Bound Upper Bound realized from importing any of the named species would be Breeders 141.7 183.2 eliminated. However, the import ban does not affect only Importers/Exporters 28.0 30.0 importers. Imported reptiles make their way through many Wholesalers 17.0 22.0 stages of the U.S. reptile distribution chain. Revenues realized Retailers 277.6 363.8 by the sale of these snakes at each stage of the distribution 11 Manufacturers 56.5 70.5 chain would also be eliminated. Food Breeders 22.0 25.5 Medical Costs 419.5 713.2 9 The industry also contended that the rule would not attain its intended effect, namely to limit the growth and spread of feral populations of the nine snakes. Reptile Show Promoters 10.0 20.0 10 See: 2009/2010 American Pet Products Association, National Pet Owners Survey. Delivery Services 5.0 7.0 11 For example, banning a Boa Constrictor prevents the sales of that constrictor Total 977.3 1,435.2 from (a) an importer to a distributor, (b) a distributor to a pet store, and (c) a pet store to a pet owner.

The cost of captive-bred constrictor pattern morphs, such as these “granite” and amelanistic Burmese Pythons (Python bivittatus), dropped precipitously after the U.S. Fish and Wildlife Service announced that they were considering a rule to list nine large constrictors as injurious wildlife.

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Exports.—Unlike imports, the proposed rule does not be limited to intrastate sales of the offspring. In short, buyers explicitly eliminate exports of the named species. However, of these snakes believe that without access to customers across federal law states that all reptiles must be exported from one the country, they would not be able to earn an adequate of 18 designated ports.12 Therefore, any business or individual return on their investment to justify their snake purchase. located in a state without a port within its boundaries would Given that breeders, pet owners, and retailers are increasingly be excluded from exporting any of the nine snakes because conducting business at reptile shows and over the internet, the Lacey Act would make it a federal offense for anyone to and given that many breeders increasingly depend on inter- transport a listed species across state lines. 13 state sales generated by the internet and out-of-state reptile Price Effects.—Major reptile business owners report that shows, if the proposed regulation passes, businesses operat- prices for each of the nine snakes have already decreased sig- ing within the confines of the Lacey Act are unlikely to have nificantly in anticipation of the Service’s proposal. Our esti- access to the critical number of customers needed to continue mates of the impact of the ban do not include the reduction operations. in the price of snakes that occurred almost immediately after the Service’s announcement that they were considering a rule to list the nine snakes as injurious wildlife. As expected, the 12  These ports are located in Anchorage, Atlanta, Baltimore, Boston, Chicago, Dallas/Ft. Worth, Houston, Honolulu, Los Angeles, Louisville, Memphis, largest price reductions have been for designer snakes, which Miami, New Orleans, New York, Newark, Portland, San Francisco, and Seattle. are more commonly referred to as morphs. Morphs are a “Bringing Pets and Wildlife into the United States.” U.S. Department of Customs and Border Protection, pp. 14–15. trade name for reptiles that are bred to have unique color 13 A review of the locations of exporters of the nine constrictor species in 2009 patterns and body types. One dealer reported that prices for within LEMIS data shows that roughly 20% of exports, by number, were some Boa Constrictor morphs have decreased from $1,000 shipped to ports located outside of an exporter’s home state. However, the 20% figure underestimates the effect of the ban on exports, since exporters often pur- to $30. In addition, many breeders (and those thinking of chase reptiles from other breeders and distributors. Some of the breeders and becoming breeders) of the nine snakes have been unwilling to distributors from which exporters purchase snakes are located in states other than that of the exporter. Thus, if the ban were enacted, the exporter would be invest in “good” parents (those that exhibit the desired genetic unable to acquire snakes from breeders and distributors located outside of his or traits) over the past few years because of concern that they will her home state. We do not know the magnitude of these interstate transactions.

In 2009, the USGS reported that the overall organism risk potential was high for Yellow Anacondas (Eunectes notaeus).

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Holding Costs.—As with any pet or stock, snakes products and services for these snakes would be realized if cost money to keep. These costs would continue if the listing the proposal were to be finalized. If the nine-snake rule were goes into effect. However, once the likelihood of selling the passed, the state of this industry is expected to fall somewhere snakes is eliminated or greatly diminished, the capital tied up between these scenarios. in housing and feeding these snakes will no longer be available Short-Term Economic Impact.—The collective industry to make new purchases and expand operations.14 As a conse- loss in revenues in the first year after enactment of the rule, quence, many breeding operations and stores would reduce assuming the low-impact scenario, is $42.8–58.7 million, and purchases of new reptiles and equipment. The decrease in assuming the high-impact scenario, is $75.6–103.6 million. purchases would negatively impact other reptile breeders, Some have dismissed these estimates as “completely bogus.”15 wholesalers, and product manufacturers. An owner of a com- However, in its economic analysis of the proposed rules, the pany that manufactures containers for snakes reported that Service estimated the nine-snake listings would result in a fear of the potential constrictor ban has already started this decline of sales of imports and domestic breed sales of the cascade of impacts. He reported that due to the announce- nine snakes of $14.7–30.1 million per year.16 The Service also ment of the proposed listing, Boa container sales have stag- reported that “secondary” economic costs of a nine-snake list- nated over the last year (i.e., 2010), leading to an increase in ing would be in the range of $42.0–86.2 million in the first inventories and a decrease in cash flow, slowing the produc- year. The Service defined secondary costs as “how the annual tion of all new snake containers. decrease (due to a decrease in retail value) in the constrictor The magnitude of the economic costs incurred by listing snake industry will affect economic output, job income, and the nine snakes as injurious wildlife depends in large part on local, state, and federal tax revenue …”17 Whether one accepts the actions of current breeders. What is certain is that a listing our estimates or the Service’s, the impact on the industry of a of the snakes will result in: (1) The lost opportunity to make nine-snake listing is substantial. legal interstate sales; (2) the lost opportunity for some breed- Long-Term Economic Impact.—While the impact of a ers to make foreign sales; and, (3) increased per-unit holding nine-snake listing in the first year alone is substantial, it is costs for keeping the snakes. Pet owners who possess but do only a fraction of the revenue losses U.S. reptile businesses not breed these nine snakes will also bear a significant burden would experience over the longer term. Revenue losses over from the listing. Owners that choose to keep rather than sell or the first ten years after an enactment of the ban are significant, dispose of their snakes will be limited in where they can move ranging from $591.5 million to $1.4 billion, based on a pre- within the United States over the course of their pet snake’s enactment industry growth rate of 7%18 (See Table 2). life, narrowing the range of their personal and career options. The present discounted value of the lost revenue stream We consider two scenarios with regard to the reaction of is between $505 million and $1.2 billion. Even assuming a industry participants if the nine-snake listing were enacted. zero-percent growth rate, lost industry revenues range from In a low-impact scenario, we posit that some breeders will $428 million to $1 billion undiscounted, or from $372 mil- continue to breed the listed constrictors, make intrastate sales, lion to $901 million, discounted. Under any of these scenar- and make foreign sales. In a high-impact scenario, we posit ios, the long-term impact of a nine-snake listing is substan- that the combination of higher per-unit costs of breeding and tial.19 Among the nine snakes, the Boa Constrictor is by far maintaining the listed constrictors as well as the reduced mar- the most economically important in terms of reptile industry ket for the listed snakes, and the concomitant lower prices, will make it unprofitable to breed, keep, and sell these snakes.

In this scenario, no revenues derived from these snakes or 14  This raises another issue involving the dilemma reptile keepers would face with existing stocks of the snakes listed as injurious wildlife. 15  Morgan, C., “Bid to Curb Nationwide Snake Sales Stalls.” The Miami Herald, Table 2. Estimates of economic impact of the nine-snake listing: 27 December 2011. First ten years (undiscounted). 16  See: Rulemaking to List Four Constrictor Snake Species Under the Lacey Act: Indian Python (Python molurus), Northern African Python (Python sebae), No Growth 7% Growth Southern African Python (Python natalensis), and Yellow Anaconda (Eunectes (Million $) (Million $) notaeus), Final Economic Analysis, prepared by The U.S. Fish and Wildlife Service. 12 January 2012, p. 4. High-Impact Scenario 18 Id at 5. Lower Bound Estimate 756.0 1,044.5 17 Exports associated with the nine snakes grew, on average, by 7% per year for the period 2008–2010 (LEMIS data). However, the general pricing trend among Upper Bound Estimate 1,036.0 1,431.4 morphs is for prices to fall as breeders produce more of the existing morphs. Our opinion is that the expected lower-bound industry growth rate (assuming a zero- Low-Impact Scenario snake listing world) is 0%, and the upper-bound growth rate is 7%. The actual growth in such a world would fall between these two boundaries. Lower Bound Estimate 428.1 591.5 19 Based on a 3.75% discount rate. This rate was the average bank prime rate for Upper Bound Estimate 692.8 811.0 2010. Federal Reserve Bank of St. Louis (http://rsearch.stlouisfed.org/fred2/cat- egories/117) (accessed 11 April 2011). 51 COLLIS AND FENILI IRCF REPTILES & AMPHIBIANS • 19(1):48–54 • MARCH 2012

The Green Anaconda (Eunectes murinus, top) is not included on the short list of four species categorized as injurious wildlife by the USFWS, but the Yellow Anaconda (E. notaeus, bottom) is. Top photograph by Lutz Dirksen, bottom photograph by Tomas Waller.

52 COLLIS AND FENILI IRCF REPTILES & AMPHIBIANS • 19(1):48–54 • MARCH 2012 revenues. Boa morphs are the most popular, and are among Table 3. Estimates of economic impact of the four-snake listing: the highest price morphs of the nine snakes. In addition, Boa First ten years (undiscounted). Constrictors account for 70% of all imports and 70% of No Growth 7% Growth exports of these nine snakes. (Million $) (Million $) Whether one agrees with our estimates of industry loss High-Impact Scenario or with those of the Service, one fact is clear — since the Service’s involvement, the uncertainty surrounding the legal Lower Bound Estimate 151.2 208.9 status of the businesses in the reptile industry has had a major Upper Bound Estimate 207.2 286.3 impact on current financial health of those businesses. The Low-Impact Scenario prices of many snakes have dropped, as buyers are hesitant Lower Bound Estimate 85.6 118.3 to purchase a snake that may be listed as an injurious species. Because of this uncertainty, both the Service’s and our esti- Upper Bound Estimate 117.4 162.2 mates of the costs of regulations are underestimated given the fact that potential future regulations affect current prices and current decisions to breed, import, and buy snakes. However, at the same news conference during which Salazar spoke, Dean Ashe, the Service’s Director, said the Listing Four Snakes: A Compromise? Service will continue to consider listing as injurious the five On 17 January 2012, Ken Salazar, Secretary of the Department other species. Ashe stated that once that process is completed, of the Interior, announced that the Service decided to list as the Service will publish final determinations on those spe- injurious only four of the nine snakes; these are the Burmese cies.22 In its rulemaking, the Service admits that the decision Python, the Yellow Anaconda, and the Northern and Southern to list only four snakes was done to accommodate the U.S. African Pythons.20 At a news conference, Salazar suggested Office of Management and Budget, and that the nine-snake that this four-snake listing was a compromise because it deals listing “… is not being rejected and the five other species … with the species that the Service considers the most immediate remain under consideration.”23 So, rather than being a com- threat to the Everglades while “not suffocating commerce by promise as Secretary Salazar suggests, the decision to list four overregulation.”21 Each of the four listed snakes was deemed by the Service to have a high organism risk potential. Of particular note, however, is the fact that the Boa 20  “Salazar Announces Ban on Importation and Interstate Transportation of Four Giant Snakes that Threaten Everglades.” U.S. Fish and Wildlife Service news Constrictor was not listed even though it was also deemed by release, 17 January 2012. the Service to have a high organism risk potential. Leaving the 21 Fleshler, D. “U.S. Bans Import of Pythons, 3 Other Constrictors.” Sun Sentinel, Boa Constrictor out of the listing considerably lessened the 17 January 2012. 22 rule’s impact on reptile industry participants, giving credence “Salazar Announces Ban on Importation and Interstate Transportation of Four Giant Snakes that Threaten Everglades.” U.S. Fish and Wildlife Service news to the view expressed by Salazar that the U.S. government was release, 17 January 2012. attempting to find a balanced solution. 23 U.S. Fish and Wildlife Service, 12 January 2012, p. 16.

Boa Constrictors (Boa constrictor) were not listed as injurious wildlife in Reticulated Pythons (Python reticulatus) are native to southeastern Asia. the 17 January 2012 announcement by the U.S. Fish and Wildlife Service. They are generally considered to be the world’s longest snakes (adults reach- This is the principal difference between the economic costs of listing four ing nearly 7 m in total length, although the average adult size is much less). versus nine species of large constrictors. Photograph by Kenneth L. Krysko. Photograph by Ruchira Somaweera.

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The Dark-spotted or DeSchauensee’s Anaconda (Eunectes deschauenseei; left) and the Beni or Bolivian Anaconda (E. beniensis; right). The former has a wide distribution in the Amazon Basin and along coastal areas to the north, whereas the latter has a range restricted to northern Bolivia. Photographs by Lutz Dirksen. snakes as injurious may be simply the first step in a process to A comparison of Tables 2 and 3 shows a large difference list all nine snakes. in the impacts of a nine-snake listing and a four-snake listing. Based on the information we have seen, we estimate that This difference is due mainly to keeping the Boa Constrictor the loss in revenues in the first year after enactment of the and, to a lesser extent, Reticulated Python imports and inter- rule, assuming a low-impact scenario, is $8.6–11.7 million, state sales legal under a four-snake listing. The difference also and assuming a high-impact scenario, is $15.1–20.7 million. represents the benefits to the industry of the compromise. These estimates are slightly lower than those of the Service, However, to the extent that the Service continues to take the which estimates that the four-snake listing will result in an position that the four-snake listing is simply an intermediate annual reduction of industry revenues of $3.7–7.6 million step to an eventual nine-snake listing, the estimated costs of and secondary economic costs of $10.7–21.8 million per year. the four-snake listing shown in Table 3 are understated and Our estimates of the ten-year impact of the four-snake listing the industry will continue to contract in anticipation of the are shown in Table 3. nine-snake listing.

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