🚀 go-pugleaf

Time is Runing out please send in your letters of support, Feel free to
quote arguments from this letter or add your own. Copies of originial
proposal are on http://www.xmission.com/~gastown/herpmed/fedreg1.htm or
contact me. 

Thanks. 

Asalzberg@aol.com



SSAR CONSERVATION COMMITTEE
	c/o 5222 N.W. 56th Court
	Gainesville, Florida 32653 USA
	kdodd@nervm.nerdc.ufl.edu


	October 4, 1996


Mr. Marshall Howe
Chief, Office of the Scientific Authority
U.S. Fish and Wildlife Service
4401 North Fairfax Drive, Room 750
Arlington, VA 22203

Dear Mr. Howe:

	The Society for the Study of Amphibians and Reptiles (SSAR) is one
of the world's largest professional herpetological societies. Our members
include academic, government, and private organization affiliated
scientists who conduct basic and applied research on amphibians, reptiles,
and the ecosystems on which they depend. We value scientific accuracy,
quality research, and integrity when reviewing issues which may affect the
animals we study and keep. 
	As chair of the SSAR's Conservation Committee, I am writing to you
in support of several recent Convention on International Trade in
Endangered Species of Wild Fauna and Flora (CITES) proposals now before
the Service. These proposals would add the following reptile species to
CITES Appendix II based on the potential for international trade to
contribute to the endangerment of wild populations: all members of the
softshell turtle genus Apalone; the alligator snapping turtle, Macroclemys
temmincki; all members of the beaded lizard genus Heloderma; the eastern
diamondback rattlesnake, Crotalus adamanteus; all members of the sawback
turtle genus Graptemys; both members of the sail-tail and dragon genus
Hydrosaurus (from the Philippines and Indonesia).
	Information on the threats to these species as well as on the
current levels of trade have been widely disseminated on the Internet, so
there is no great need to reiterate them here. This information has been
reviewed by most of our Committee members and no factual errors have been
reported. We are particularly concerned about the trade in North American
freshwater turtles for both the pet trade and the international food
markets, especially in Asia. As you well know, the life histories of these
long-lived vertebrates make them extremely vulnerable to take. Populations
will take a very long time to recover from the levels of trade currently
being reported.
	Of course, we are well aware that certain species of Graptemys
seemingly are still abundant in parts of the country. Other species
(oculifera, flavimaculata) are protected by US federal law and
cannot in theory be traded. However, there are many as yet unlisted
species of Graptemys that are extremely vulnerable to take, including
barbouri, caglei, ernsti, gibbonsi, nigrinoda, pulchra and versa. We
consider these species to be in need of protective measures in order to
ensure population viability, and they certainly should not be exported
without knowing the precise effects that take is having on our already
declining populations. Indeed, we are at a loss to understand how any
native amphibian or reptile can be exported in the volume reported for
many species without considerable concern by federal agencies as to effect
on native populations. US species should not be subject to indiscriminate
exploitation to satisfy the whims of foreign markets.
	The SSAR Conservation Committee is aware that CITES is a trade
convention, not an endangered species convention. Because of the potential
effects of take (=international trade) on all of the species listed above,
especially after considering models of take on long-lived vertebrates with
high adult survivorship and low levels of recruitment, we can see no
recourse but to list these species on CITES Appendix II. Listing will not
prevent trade, of course, but it will allow for an accurate monitoring of
trade as well as provide the impetus for determining exact biological
effects on populations. International trade may only be allowed so long as
sound biological data support the decision that trade will not adversely
harm native populations. No one who cares about the future of these
species should have a problem with ensuring that sound science supports a
management decision. 	Ultimately, of course, we must find a way to
protect the natural habitat of these species. No listing, whether on
federal list, state list, or international treaty, will ensure the
long-term survival of our amphibian and reptile species without attention
to their habitats. We urge the Service to develop ways to conserve natural
habitats and the biodiversity they contain before protection becomes
necessary for so many species.
	We would be happy to answer any questions you might have, or to
direct your questions to appropriate scientists. Please let us know of
your decision. Thank you for your attention in this matter.




					Sincerely



					C. Kenneth Dodd, Jr. Ph.D.
					Chair, Conservation Committee
					SSAR