CITIZEN-PROPOSED ISSUE PAPER Date: 08-27-2015 ISSUE: Putting the Two-toed Sloth on the unregulated list for CO DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE): See attached

WHO MIGHT BE INTERESTED IN THIS ISSUE? HAVE YOU COMMUNICATED WITH ANY OTHER INTERESTED PARTIES? WHAT INPUT HAVE YOU RECEIVED? I may be the only person interested in this animal as a pet. I’ve not heard from anyone since I began this endeavor. When I bring it up to people I know, they’re shocked that anyone would want to own one. That being said, I live in a smaller community, in the larger cities they may be more desirable. Everyone that I do tell are thrilled to be able to know someone who owns one and would love the opportunity to pet one.

ALTERNATIVES: PLEASE INDICATE THE PROBABLE OUTCOME IF THIS PETITION IS ACCEPTED, AS WELL AS THE IMPACT OF ALTERNATIVES TO THIS PETITION: This would allow me to be able to obtain a sloth as a pet. As demonstrated in my proposal, there are no adverse effects on the current wildlife or their habitat by allowing the sloth to be unregulated. If we can’t put them on the unregulated list, I would like it to be considered making it possible for a permit to be issued to own one.

PETITION PROPOSED BY: Darcy Sanborn PETITION WRITTEN BY: Darcy Sanborn DATE SENT TO THE 08-27-2015 COMMISSION:

1 WHO MIGHT BE INTERESTED IN THIS ISSUE? HAVE YOU COMMUNICATED WITH ANY OTHER INTERESTED PARTIES? WHAT INPUT HAVE YOU RECEIVED? Recent interest in sloth care and it’s status in the wild is wide spread. People with an interest in preserving the delicate balance of the rainforest always have a keen interest in what they can do to preserve it’s inhabitants. Domestic imports of two toed sloths into the U.S. number 119 annually, most of which go to the private sector. These are the people most effected by exotic animal regulations. With significant new hurdles now accomplished, successful sloth husbandry has become something possible to people in areas of the U.S. previously impossible including Colorado. In an increasing hands on approach to environmental stewardship, potential, and present sloth keepers want to be part of the groundwork to preserve this animal by being a member of a network of keepers with the intent of captive breeding. Only with the participation of qualified keepers will the captive population of U.S. sloths be developed and available if and when, the status of the sloth changes. Sloth keepers as well as the scientific community agree, we are entering the next great era of extinction. We will witness the loss of many great species. Since the earliest recordings of animal species to present day we have lost over 50% of the animals that inhabited the earth. Sloth keepers believe in a hands on approach to rainforest stewardship. So little is known about the habits and requirements of the two toed sloth that if a significant number of people don’t step in, it’s future may be threatened. Only by allowing the keeping of sloths in the private sector, will the accumulation of animals in this invisible Ark be established. When we refer to the invisible Ark we refer to the vast holdings in the private sector of rare and endangered animals, legally and responsibly kept. These animals are maintained without state or federal funds, they require no donations, trusts, or contributions. They are simply maintained by the focused intent of the private keeper. Although the other keepers I’ve had communication with are not Colorado residents they have encountered similar regulations which group sloths as exotic animals that were prohibited or in need of regulation. With education the state of Utah recently amended their regulations for the city of Salt Lake to allow a private keeper to obtain a sloth. Other states with climates more suitable for invasive species from the rainforest allow sloths with simple class 3 permits, including Florida and Texas. As a U.S. citizen one of the inalienable rights I’m entitled to is the pursuit of happiness, regulations restricting my importing a non-invasive and harmless animal into Colorado to further conservation stands in the way of my pursuit of this happiness.

ALTERNATIVES: PLEASE INDICATE THE PROBABLE OUTCOME IF THIS PETITION IS ACCEPTED, AS WELL AS THE IMPACT OF ALTERNATIVES TO THIS PETITION: Allowing the deregulation of two toed sloths in Colorado will show the state’s willingness to examine and change laws which put unreasonable hardship on animal keepers when shown evidence of them being non-invasive, harmless and of no threat to native wildlife, agriculture or residents. Recognizing the benefits of homegrown efforts to preserve vanishing species by adjusting regulations goes a long way to show the state of Colorado has a commitment to the needs of it’s residents. Acceptance of this petition specifically allows the authorized import and keeping of the two toed sloth. An acceptable alternative would be to allow a permit to be issued without the changing of the regulations that would exempt the petitioner and allow the import and keeping of a two toed sloth.

2 3 To whom it may concern;

I am writing to request your consideration in the matter of allowing the Two-toed Sloth to be included on the unregulated list for wildlife in the State of Colorado. Species: Choloepus Linnaeus (Linnaeus' Two-toed Sloth) or Choloepus Hoffmann (Hoffmann's Two-toed Sloth). Family: Megalonychidae, Genus: Choloepus. I would like both species considered for the list. The two-toed is the only type of sloth that can live in captivity; therefore, I would not consider the three-toed as an option. In this proposal I will answer all of the questions necessary to make your determination.

I would first like to stress the fact that Sloths, by nature, are NOT aggressive or dangerous. They are docile and slow moving. The fact that they are tropical and live in the rain forest means the Sloth does not have the ability to survive on its own in the climate of Colorado. In the event they would "escape" or even be let go on purpose, the Sloth would perish on its own. We don't have their natural food source, nor can they maintain their own body temperature; therefore the cold temperatures in CO are not conducive to life for them. In the event they were to escape, sloths move so slowly that they would be easily recaptured.

They do not mate with any other species; therefore, there is no jeopardy of inter species mating. They only mate once a year and only have one off spring. Their gestation is 9 to 11 months and they only mate if their current infant is completely weaned and on its own. They are solitary animals and very slow, so there are times when they miss the mating season all together, which is commonly “the dry season” in the wild.

There is no danger to agriculture or native wildlife as previously stated Sloths cannot survive out of captivity in this State. They require humidity and warmth in order to survive. Their natural habitat is the rain forest; CO is not close to that.

Sloths are not dangerous; they are herbivores, so they will not prey upon natural wildlife, or any animal. In captivity there is a specific diet which can be purchased online; Marion leaf eater food. You supplement their diet with spring mix lettuce and sweet potatoes. They also eat carrots, green beans and squash. Sloths can take up to one month to digest one meal due to their very slow metabolism. There is no danger to native vegetation as they do not eat enough to make an impact. Not to mention, they cannot survive on their own.

Sloths do not have any zoonotic diseases. In their natural habitat they are a host to microorganisms and have multiple bacteria in their fur. In captivity they do not, as they don't have the same habitat. They have intestinal parasites, again not in captivity. The parasites are from their natural diet, which they don't eat in captivity. There are several studies about sloth fur. The belief is that in the wild the fungi in sloth’s fur have medicinal benefits. The studies believe that their fur contain fungi that could possibly one day help in the fight against breast cancer and treat various other diseases. The studies are still in progress and have a long way to go, but so far the results are looking favorable. I’ve had a discussion with Dr. Schotman, DVM, who currently has over 10 years experience working on sloths. He has never seen any

4 zoonotic diseases or any of the natural intestinal parasites that they have in the wild in the captive sloths he’s dealt with. Please see the attached email from Dr. Schotman, DVM for his added information on the topic.

The "weediness" of sloths is nonexistent. They are not aggressive, they cannot survive, let alone thrive in CO. Sloths do not inter breed or adapt to other food sources. The natural vegetation in CO can be eaten by sloths, but they require a little more nutrients in order to sustain life, so on their own in the wild would be a difficult task at best.

Finally, I contacted the Departments of Wildlife in Arizona, Utah, Nevada, Wyoming, Nebraska, Kansas, Oklahoma, New Mexico, Idaho, and Montana, to get their regulations on sloth ownership. Nebraska is the strictest; they do not allow any wildlife that is nonnative, so sloths are prohibited. Arizona has them on their restricted list; however, you can get a special license to own them. Nevada, New Mexico and Wyoming require a permit to own one, but each agency said the sloth was considered to be not dangerous or invasive to the natural wildlife, so they would have no problem issuing a permit upon request. Kansas, Oklahoma, Idaho, Montana and Utah all have no regulations on them and they can be owned with no restrictions. The only exception is Idaho does require a health certificate in order for them to be imported. I spoke with the Department of Agriculture and the state Veterinarian in Idaho and Oklahoma, because an exotic animal falls under their guidelines for those states. Those departments also said the sloth is not harmful to the environment and not considered an aggressive or dangerous animal to own, therefore; there is no regulation on ownership.

In the state of Montana they recently (2005) admitted the sloth to their “domesticated non regulatory” list. I’ve attached their process in making their decision. As a state, they form an independent committee comprised of DOW members, veterinary staff, Department of Agriculture people and citizens. Once that committee researches the animal in question they make a recommendation to the Commission for or against the animal. As I previously stated, their recommendation was to make the sloth acceptable to own in their state. They actually have several people who currently own them now. There are individuals in Idaho, Kansas and Utah that also currently own the sloth as a pet.

On a personal note, I work for the only exotic Veterinarian in our city. We deal with the kangaroos, wallabies, and sugar gliders in town; animals that are currently on the unregulated list. Those animals can be very aggressive and are often time hard to handle. The sloth would be very similar to having a hairy box turtle in comparison. As with any animal, wild or domestic, you should always take care when handling so as not to get hurt. You can be injured by any animal if you do not take the appropriate precautions domestic or otherwise.

This is a link to a brief video (approximately 15 minutes) for “sloth care”. It demonstrates how docile this animal is and what is required to care for them as juveniles. As they grow up their care is not as intense, but they will always require some degree of care. https://docs.google.com/file/d/0B0b0wm2YibDETy1DeEZXanZSQ1k/edit?usp=drive_web I hope this helps to clarify their care and habitat in captivity.

5 In conclusion there are no adverse effects in the State of CO for sloth ownership, only the benefit of a slow moving, docile, huggable companion that will live a long happy life with the right environment.

Thank you for your consideration in this matter.

Bibliography: - San Diego Zoo Library - Emmons 1990 - Gilmore 2008, 2000 - Merritt 2006, 1985 - Montgomery & Sunquist 1973, 1978 - Ramprashed 1985 - Goffart 1971 - Parra 1978 - Rosenberg & Maliniak 1985 - Nowak 1999 - Taube 2001 - Smithsonian Tropical Research Institute - Higginbotham, S., et al 2014 - Dr. Tom Schotman, DVM

6 First, I’d like to say thank you for allowing me to come back to re-address my petition to have the two toed sloth added to the unregulated list. I’d like to address the four concerns and consequently what I believe were the reasons for denial.

1. Zoonotic diseases: I’ve been able to review and included copies of the two studies that the staff was able to find and brought up last time. I’d like to point out that in both of these studies; although they say they’re from “captive” sloths, these sloths were in their natural habitat. One study was done in 1999 at the rescue in Costa Rica. Yes, the sloths there are in captivity, but they were taken there directly from the wild and are kept in their natural wild surroundings and climate. The other study was done in 2009, this study was done in Brazil, again the natural habitat for sloths. These sloths were in a zoo situation and kept as much in their natural wildlife habitat as possible, which allows the parasites and diseases of the rain forest climate to continue to be on them. In the United States we do not have that same climate or habitat they have in either of these studies. The diseases listed; E-coli, Salmonella, toxoplasmosis, histoplasmosis, and Leishmania are all common zoonotic diseases found in dogs, cats, reptiles, and multiple other domestic animals currently. Trypanosoma brucei is only found in Africa, Central America and Latin America, it is spread by the tsetse fly. The only cases that have been found in the US were people who’ve come in from Latin America, Central America or Africa. I’ve included copies of UC Davis’ information about zoonotic diseases in sloths, armadillos, and ant-eaters. (The closest relative to the sloth is the ant-eater and the armadillo). According to their information dated 11-15-2015, the only zoonotic disease they’re aware of is Leporsy. That being said, they’ve specifically said that sloths and ant-eaters DO NOT HARBOR this virus. It is only found in armadillos, but because they’re in the same “family” it’s listed as a disease for all of them. The other study I found that showed a zoonotic disease for sloths was done in 1985. The Oropouche virus (upper respiratory) was listed as being found only in THREE TOED, not the two toed. I’ve provided the email from Dr. Schotman D.V.M, who works at Lake Whales Veterinary hospital in Lake Whales, FL. He is the leading expert on sloth veterinary care. He has done over 50 fecals on domesticated sloths and found no sign of parasites or zoonotic diseases. I know that 50 doesn’t seem like much, but when you consider that only 2 to 4 sloths are brought into the US a year, that’s quite a bit. I’ve also talked to Dr. Poutous, V.M.D, who works for Midway Veterinary Hospital in Chesapeake, VA. He is the veterinarian currently handling my friend’s sloth (in addition to others) in VA. He performs routine fecals on her yearly and he has found no zoonotic diseases or parasites either. I’ve included an email from him as well. I’d like to mention there is a federally funded Sloth sanctuary, The Zoological Wildlife Conservation Center and Sloth Captive Husbandry Research Center in Rainier, OR. They are well known for having the largest population of adult sloths in captivity in the Unites States. They also have an established captive breeding program. One of the reasons they’re still able to remain open is through their sloth programs. In addition to being federally funded they receive monies from citizen who frequent their facility and “spend the night with a sloth”, “feed a sloth” or “kiss a sloth”. They have several programs that, like I said, are frequented by multiple people throughout the year. There is no way this facility would be able to have these programs if there was any possibility of sloths transmitting any zoonotic diseases. 2. I understand the idea of not keeping wildlife as pets. However; when the natural habitat of the species is being destroyed and they’re being killed at an alarming rate, why not? Should we wait until they’re completely extinct before we take action to conserve them? In captivity, we are able to give them better food, a better environment free of predators, and love and affection that they would not have in the wild. They live longer in captivity because we’re able to provide those things.

7 I would never suggest that you keep a mountain lion as a pet, they’re very dangerous and could injure if not kill you, but there is not that danger with a sloth? The sloth sanctuaries are over run with sloths that are being driven out of their homes. do to over population of humans in their habitat. There is also documented cases of birth defects because the sloths are not able to get past the human population to mate with other sloths that are not related. It’s becoming harder and harder in the wild for them to survive, so bringing them into captivity is a step in the right direction to preserve this awesome creature. 3. As far as the black market is concerned, I’d like to read the email from Pete, the owner of the pet shop whom I’ve been dealing with. In his email, he’s included his licenses and permits to sell and acquire exotic animals. It is LEGAL to import sloths into the United States; there’s no reason to do it on the black market. Commissioner Zip inquired as to his permits to bring them into the United States, you’ll see them attached to the email. 4. Finally, the fact that there are not a lot of people interested in owning a sloth as being a reason for denial, does not seem fair. It goes along with the black market, if there is only one person (me) you know they’re not getting them from the black market. I stand by my early comments; if you’re going to pay the money and look into getting this as a pet, you’re going to be able to take care of them like they need to be. The states around us that currently allow the sloth as a pet don’t have very many either. Montana has 3, Utah has 2, and Idaho has one. I don’t see the problem with having one, maybe two, in the State of Colorado. I really don’t see that as a reason to deny the petition.

There was mention of sloths being “nonnative”. Again, I don’t see that being a good enough reason to deny them. There are more animals that are nonnative on the list then I can count on both hands; wallabies, kangaroos, sugar gliders, hedgehogs, iguanas, pythons, every tropical bird; parrots, macaws, hyacinths, amazons and the list goes on. I’d like to take a minute to compare just with the wallaby.

• Wallabies are imported from Australia and New Guinea so the likely hood of black market sales are equal to that of the sloth. They are both legal to import, so it seems unlikely that someone would risk imprisonment for black market sales.

* Wallabies do have zoonotic diseases; per

Dr. Bob's All Creatures Site WWW.Petdoc.ws

* Anthrax • Dermatophytosis • Leptospirosis * Meliodosis • Mycobacterium bovis • Pasteurella multocida • Q fever • Salmonellosis • Scabies • Sparganosis • Trichinosis

8 Just to name a few. You will not convince me that domesticated (in the US) sloths have any zoonotic diseases.

* Wallabies can be very aggressive and they’re very fast. They have razor sharp claws that are used as a defense mechanism. Sloths are not aggressive or fast. Their claws are used as fingers and are not used for defense. Their defense mechanism is to be still.

*Wallabies can be invasive as they do eat the natural crops in CO whereas, sloths do not and could not survive if they were to be out of captivity.

I understand that the commission, for the most part, rules in favor of “the staff” in these cases; however, I do not believe they have proven their case. I’ve given you documented evidence to back up my findings and to contradict that of the staff. I would hope that you will take this into consideration when deciding on my petition.

Thank you,

Darcy Sanborn

9 As a supplier of Two Toed sloths with over 17 years of experience keeping sloths it has become increasingly clear that the popularity of these gentle animals has increased to a level of admiration seldom seen in the pet trade. Interestingly the amount of effort to obtain sloths has not become any easier, if anything it’s become harder. Significant advancements in the care and husbandry has taken years to achieve, but finally we are moving in the direction where we can confidently say we can keep this interesting animal alive and healthy. Only a few years ago the mortality rate in zoo kept sloths was over 60%. With a more detailed understanding of the diet, temperature and humidity levels necessary for successful sloth husbandry, sloth care has moved light years ahead of where it was less than a decade ago. This is mainly because the private sector has invested so much time breaking the husbandry codes to keep them successfully in captivity. The next hurtle will be captive breeding, which up to this point has only occurred sporacticly at best. A few zoos and private keepers have had captive breeding success and a few more private keepers have had captive births from wild matings. To advance captive breeding, baby sloths need to be established in captivity and grown for the 3 to 4 years it will take to reach maturity and selectively bred to eliminate the need for imported sloths as well as to secure a population safe from environmental challenges. Conservation challenges of Two Toed sloths include the loss of habitat, climate change, and hunting for bush meat. Presently listed on the wildlife red list as a species of least concern, the two toed sloth has largely been overlooked. Understanding that waiting until a species is in peril is the wrong approach to preserving it, interested sloth keepers have formed a network of U.S. keepers. Participating in Sloth Blogs, internet forums, and social media, keepers share experiences and milestones in captive husbandry. Long gone is the idea that people in the private sector are unable or shouldn’t be a part of serious conservation involvement. Instead contempory observers have seen the complete ability of private keepers to not only have success with species never bred in captivity but significant husbandry milestones achieved that were elusive to even some of the nation’s top zoos. In the captive breeding of rare reptiles for instance, the private sector has bred nearly every species of Python in the world, while all the zoos in the world achieved only a fraction of this success. Why is the question. The answer is rather simple, and revolves around the dedication of raising a target species by people participating in an economically driven model of conservation. The easy access to high end electronics to replicate climate challenges and the information access to native range climates in a real time setting are just some of the parameters available to private keepers that contribute to their success and drives the keeper to constantly seek what others can’t achieve. Add to that the availability of high end zoo type diets via the internet and the availability to advanced animal veterinarians for medical care and the scenario is set in motion. Some of the last hurtles for sloth ownership are states that have passed blanket regulations prohibiting exotic animals to be kept as pets. Considering the nature of sloth keeping, maybe a new category of animal care should replace “pets” in this instance, it should be deemed as “animal stewardship”. Regulations are needed for animals that pose a threat to people and wildlife, as well as commercial livestock but the non-invasive and harmless nature of sloths places them in a category best described as harmless. For states with temperate climates like Florida and Texas where invasive animals are well understood and regulated they are allowed with a simple license. This identifies where the animals are held and gives authority to the wildlife agency to issue cage guidelines and authorizes inspections to ensure animals are kept properly and humanely. Interestingly in the state of Florida, which has the most invasive animal problems of any state, the Florida Wildlife Conservation Commission relies heavily on the private sector for advice, and involvement with regulations, a relationship that has been beneficial to both the state and it’s human and non human inhabitants. Utah and Montana are two states that recently revisited their regulations on keeping sloths and now allow private keepers to have them. Most other states have provisions in place to allow the keeping of sloths, recognizing them as a non threat to people and the environment. Simply stated they are too specialized, too slow and delicate to survive without a educated keeper in almost any part of the country except extreme south east United States. They pose no danger to people

10 from disease transfer, have not been known to carry internal parasites and in most cases could not significantly injure someone unless they were asleep. With all this in mind it seems that educated lawmakers could only conclude that authorizing sloth keeping in the private sector certainly should be allowed with oversight. Pete Bandre Owner of Incredible Pets Inc. Melbourne, Fl.

Sent from Mail for Windows 10

11 Subject: Re: Email To: darcy Cc:

Yes I did sorry Here's copies of my licenses.

Federal import permit

12 USDA permit authorizing me to sell exotic animals

13 State permit authorizing me to sell exotics.

The notion that anyone would consider even the possibility of these animals being in the Black market is so ridiculous. These are legally allowed to be imported and are under the authority of CITES, The Convention for International Trade of Endangered Species. They are inspected by the Guyana Wildlife Authority after a health certificate is issued by a Federal Veterinarian. They are then inspected at arrival by US Fish and Wildlife, US customs, and Homeland Security. Further they are issued a US health certificate which screens them for parasites before interstate travel. We have done fecals for parasites on over 30 imported sloths and everyone was negative. Who in their right mind would risk prison to smuggle a non endangered animal allowed for export when it can be done legally, that's just stupid!

14 15 16 17 18 19 20 21 22 23 24 25 26 CLASSIFICATION OF EXOTIC SPECIES

RECOMMENDATION BY THE CLASSIFICATION REVIEW COMMITTEE

COMMON AND SCIENTIFIC NAME: TWO-TOED SLOTH (FAMILY MegalonychidaeCholoepus didoctylus) RECOMMENDED CLASSIFICATION: UNCONTROLLED

Current Classification and Control Two-toed sloths are listed on CITES but are not currently listed as endangered.

Environmental Impacts Two-toed sloths live in equatorial regions of Central America and northern South America and could not live in Montana if they escaped or were intentionally released. They present no potential for significant environmental impacts.

Health or Safety Risks Although seemingly slow moving, sloths can strike fairly quickly with their long forefeet, which have large, hooked, sharp claws. They also use their teeth effectively, and both means of defense can inflict severe wounds. There are no known zoonotic diseases associated with two-toed sloths.

Recommendation

The Classification Review Committee recommends that two toed sloths be listed as uncontrolled for private possession in Montana. It is not expected that many two toed sloths will be imported into Montana. This request was generated by an individual who has possessed two toed sloths for many years and is moving to Montana. The individual has experience and training in the care of these sloths.

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