Dear Editor,
I am a responsible Wisconsin reptile keeper who opposes some of the proposed changes to the state’s herpetology regulations. Other Wisconsin herpetoculturists and I care about the conservation of our native herps and fully support some of the herp rule amendments, but aspects of this proposal will do more harm than good by incentivizing poaching and illegal activities. Some of these provisions go way too far in that they restrict even kids from having pets and nature centers, etc., from exhibiting common species of herptiles. Yes, there are diseases amongst our wild populations of herptiles which need to be addressed. However, banning the possession and breeding of these animals due to disease concerns seems very extreme when there are many less restrictive alternatives that exist.
Many native species of amphibians and reptiles are commonly maintained as pets. Breeding and selling state-native herps should be allowed. Some state native species, especially bullsnakes, ratsnakes, and many native turtle species, have been bred by herpetoculturists for decades and are common pets. People seeking pets want captive-bred animals and not wild-caught. Across the country, we are seeing bans cause the black market price to skyrocket, and our wild-caught animals are being smuggled. Yes, our wild animals need protection, but blanket bans are counterproductive. There are alternatives that protect the wild animals and allow good herpetoculturists to work their species of choice. The Department also has not cited sufficient data or evidence that wildlife disease concerns necessitate banning all keeping of these animals in captivity. To the contrary, this will only encourage people to dump their unwanted pets, many of which they may have had for many years, into the wild as they attempt to comply with an unenforceable “24-hour” time limit.
Also, contrary to what has been reported by staff, some neighboring states, including Illinois, absolutely do allow the propagation of state-native herps and the sale of those animals bred under human care. This breeding and selling applies to pet animals, not just those used for research or recovery. Under current regulations, “captive-breeding” is also actually allowed, as long as an individual is otherwise within the possession limits for the species that they have, and the “offspring may not be sold, traded, or bartered.”
It is also unclear as to what licensing all non-commercial display and exhibition of native herps is meant to accomplish other than more licensing and overreach. This will only discourage education and outreach efforts from doing much needed work and/or cause them to resort to utilizing exotic/non-native species ill-suited for native species topics and presentations.
This rule, as it is currently written, is far more restrictive than any of the other upper Midwestern states compared in the rule’s documents, which raises serious concerns regarding both fairness and practical enforceability. Enforcing a “24-hour” possession timeline on captive-bred pets that have existed in herpetoculture for many decades makes no sense and would be practically unenforceable. Please seek practical and reasonable rules rather than overreaching bans. Responsible Wisconsin herpetoculturists such as myself will gladly collaborate on this matter.
Our Wisconsin amphibian and reptile regulations must be based on practical realities and scientific evidence, not just on paper for administrative convenience. Thank you for your time.
Eric S. Roscoe
Specialty Serpents