Nonnative Wildlife Invasion Prevention Act (HR 669)

PetSmart, our friends in the pet specialty industry and pet parents are watching closely a proposed new regulation beginning to inch its way through Congress. The Nonnative Wildlife Invasion Prevention Act (HR 669) proposes an unreasonably complicated and ineffective process to determine which non-native species can be in the country and which ones can’t, including species (many enjoyed as pets) that already are well established in the U.S.

The bill creates severe restrictions that could adversely impact the importation, breeding, sale, or interstate transport of common household pets such as gerbils, hamsters, guinea pigs, fish, and various birds, reptiles and amphibians in the U.S. A coalition of animal rights and environmental groups including the Humane Society of the U.S. is pushing for the bill’s passage. 

While PetSmart agrees with and supports the underlying premise of the proposed regulation – to keep harmful non-native species out of the country – we oppose the proposed legislation on several grounds. More specifically:

• We support a process that more fully takes into account the risks associated with various species based on sound scientific data. 
  
• We believe the current drafting of the bill does not take into account existing protective measures, the impact to pet parents and the economic impact on the pet specialty industry. It also requires funds and staffing not currently available to the U.S. Fish & Wildlife Service, which would be tasked with administrating and enforcing the regulation. Moreover, it could lead to the mass release and/or euthanasia of pets. 
  
• We believe a more practical and meaningful regulatory process could be developed and implemented in a timely manner. Along with our industry partners we’ve offered our expertise to help craft legislation that is more reasonable and still achieves the desired intent.
  
• We believe the small pets, reptiles, fish, birds and amphibians we sell currently meet the intent of the bill and do not create any of the risks outlined in the proposed legislation, yet virtually all of them would be in jeopardy under the bill as currently drafted.
  

A hearing on the bill is scheduled April 23 in the House Subcommittee on Insular Affairs, Oceans & Wildlife. PetSmart will be represented at the hearing by the Pet Industry Joint Advisory Committee, a pet industry trade organization of which we are a member.

We will continue to advocate for a more effective approach to regulating harmful non-native species.

Dear Subcommittee Members,

We have reviewed HR 669, The Nonative [sic] Wildlife Invasion Prevention Act. While we applaud the intention of the resolution, we are concerned that there will be substantial unintended consequences from the bill, as written, that would be devastating to the $278 million/year aquarium fish trade and to aquatic life, both cultured and wild harvested. These negative consequences include both adverse effects on rural poor and on ecosystems of critical biological importance.

For more than 20 years, the New England Aquarium has been involved in research on the global trade of aquarium fishes. We have noted numerous situations where the fishery harvest has a negligible impact on the long term stability of commercialized species, but is very important to the local economy. Many of these fisheries play a critical role in rural communities and are a sustainable resource that provides much needed livelihoods. Because of their reliance on these fisheries, and the dependence of the fishes on healthy habitat, the people of these regions play an important role in managing their environment in a responsible manner. Many local communities know that in order to maintain their economies and way of life, they must protect the ecosystems within which targeted species thrive.

These ecosystems include reef ecosystems, riverine ecosystems, and vast tracts of flooded Amazon rainforest. The latter are of critical ecological importance not only locally and nationally, but globally in terms of their biological diversity and their role as carbon sinks. Protecting sustainably harvested fisheries can, therefore, provide significant environmental benefits.

In general, the ornamental fish trade is one that provides substantial jobs and income, not just to rural communities in Latin America that have few other options, but also to many people in the US and Europe. Globally, the ornamental fish trade is a multi billion dollar industry. HR 669 as it is currently drafted could result in the loss of substantial revenue for small businesses throughout the country during the already serious economic downturn.

Many of the community-based fisheries already face a variety of threats and challenges. At the New England Aquarium, we have been developing a strategy that will help these fisheries move toward full sustainability, reduce or eliminate ecosystem threats, and take advantage of opportunities to maximize benefits. Central to this strategy is the development of internationally recognized certification system of Best Handling Practices, with routine disease screening, and biosecurity measures. Species that represent a threat of dangerous introduction to the US will not be included.

We urge the subcommittee to amend HR 669 to protect critical ornamental fisheries and prevent adverse effects on the regions and the people that depend on them.

There are effective means, other than HR 669, to reduce the introduction of exotics. An excellent model, the Responsible Fishkeeping Initiative, exists in the Northeast region. The Initiative is working in partnership with retail pet shops who, on a voluntary basis, are taking a pledge to discontinue the sale of fishes inappropriate for home aquariums. Also, to provide an alternative to releasing problem fish into local waters, participating retailers have agreed to take in unwanted pet fish and either euthanize them or secure new homes for them.

We are willing to assist the subcommittee with technical input in the areas of ornamental fisheries and invasive species to create a resolution that will better protect marine and freshwater ecosystems, support local communities that harvest fish sustainably, encourage responsible fishkeeping in the U.S., and protect the small businesses that depend upon this trade.

Sincerely,

Bud Ris
President & CEO

U.S. House of Representatives Committee on Natural Resources
Subcommittee on Insular Affairs, Oceans and Wildlife

Dear Subcommittee Members,

We have reviewed the Nonnative Wildlife Invasion Prevention Act HR 669, and thank you for the opportunity to comment at this time. We agree that invasive species create serious risks to our native biodiversity, and we strongly support your interest in working to prevent future wildlife introductions in the USA.

The World Parrot Trust is an international, member-based organization, with a focus on the conservation of endangered parrot species in the wild, and the welfare of the millions of these birds living in captivity here in the USA and abroad. Because wild parrots are often threatened by both invasive species and the international trade in wild birds, we have extensive experience recognizing these threats and responding with creative and effective solutions.

For the past 20 years, the World Parrot Trust has been a leader in ending the commercial trade in wild caught birds. We are staunch supporters of our Wild Bird Conservation Act, and we recently lead a campaign to urge the EU to adopt a similar policy. This EU campaign – which was supported by the American Bird Conservancy, Defenders of Wildlife, and the Humane Society of the United States and 230 other NGO’s – came to fruition in 2007 with the EU following the USA’s example.

With regard to invasive species here in the USA, the best available science is remarkably clear; past introductions now have profound impacts to both our ecosystems and our economy. We applaud this committee’s interest in meeting existing and future challenges of this kind. As we have outlined below, the risks created by the ownership of exotic pets are by-and-large inconsequential, and the most threatening risks both in the past and the present, come from a number of categorically different sources. We hope your review will help clarify these essential distinctions, and lead you in the direction of more focused and effective solutions to these problems.

Exotic pets and American ecosystems:

In their scientific review of the current state of invasive species in this country, Pimentel et al* compiled a complete and rigorous evaluation of the sources and the impacts of animal and plant introductions. Most crucially for HR 669, among the long list of important invasive mammals, birds, reptiles, fish, and insects (Table 1), none of these listed species were introduced as a result of the keeping of exotic animals. Not one.

The listed species of greatest ecological or economic impact fell into one of three categories: 1) accidentally introduced pest species like rats or the brown tree snake, 2) purposefully introduced biological control agents like mongooses and House Sparrows, or 3) escaped domesticated pet species or livestock like cats, dogs, and pigs. HR 669 makes no attempt to address any of these threat categories, but instead focuses on exotic pets which this research found to be comparatively inconsequential.

Naturally, there are a few exceptions, both because some species have great invasive potential, and because some parts of the USA which are uniquely capable of supporting non-native wildlife. However, when adopted in a timely fashion, legislation at the state level has been an effective response to these concerns, and we strongly support this targeted approach to prevent such invasions on a case-by-case basis.

As crafted, HR 669 ignores sound science on established problems and known risks, and instead targets millions of American’s exotic pets which themselves create almost no measurable risk to native wildlife.

Foreseeable adverse consequences:

If the motivation of HR 669 is in fact to prevent the introduction of non-native species, it would appear counterproductive to take steps which will predictably lead to the liberation of millions of pets into American ecosystems. Should the bill be adopted, many pet owners will live in fear that their animals will be confiscated, or that they will be penalized for possession. Many will feel that releasing their pets into the wild is a better fate than turning them in to authorities or euthanizing them, leading to the liberation of large numbers of exotic animals into the wild. Although most of these animals will perish – itself a cruel and unnecessary outcome – some will survive and establish new populations of non-native wildlife all across the country, which is precisely the opposite outcome of what this bill intends.

In addition to encouraging the release of exotic species, HR 669 can also be predicted to cause millions of exotic animals to be relinquished to exotic animal rescue facilities which are already dangerously overpopulated. The ownership provisions and the prohibitions on interstate travel with exotic pets coupled with our highly mobile society will ensure that millions of Americans will face the difficult choice of either acting criminally and continuing to care for their pets, or following the law and giving them up. This bill will therefore create an animal welfare crisis on a scale which is difficult to fathom. The current network of such facilities – accredited or otherwise – is already overburdened by an existing need which is tiny fraction of the demand created by HR 669.

In sum, we applaud this committee’s willingness to address the risks of introducing non-native species into natural ecosystems here in the USA. However, as currently crafted, HR 669 avoids addressing the most serious invasive species problems and the most threatening risks of future introductions. Moreover, this bill would inevitably create problem of its own, including the release of millions of animals now in captivity and the relinquishment of millions of pets into institutions ill-equipped to cope with their numbers and diversity. We urge this committee to give due consideration to the best available science and to focus your invasive species concerns on a new and more practical solution which targets the root of the problem rather than avoiding it entirely.

Sincerely,

James D. Gilardi, Ph.D.
Executive Director

• Center for International Environmental Law
• Defenders of Wildlife
• Ecological Society of America
• Environmental Law Institute
• Great Lakes United
• Healing Our Waters-Great Lakes Coalition
• Lady Bird Johnson Wildflower Center
• National Association of Exotic Pest Plant Councils
• National Audubon Society
• National Parks Conservation Association
• National Wildlife Federation
• National Wildlife Refuge Association
• Natural Areas Association
• Natural Resources Defense Council
• The Nature Conservancy
• Union of Concerned Scientists

This is known as capwiz: <http://capwiz.com/naiatrust/home/>

I agree with some of what Leigh Ann says: there are just too many “ignorant” people out there that have no clue how to care for animals that have complex needs. But if we were to take Leigh Ann’s logic a step or two, we would ban people from having children because there are people who batter and abuse their children, because they are ignorant and do not know how to care for a child. This is such a poorly constructed bill. It even redefines “importation” and overrides existing US Customs law. It provides no solution for pets other than than euthanasia. No doubt by some of those same ignorant people. The American environment is being decimated but it is not from animals that are being released by pet owners who wake up one day finally getting it that the chimp in the next room can eat their face, or the alligator at the foot of the bed can swallow their leg, or that boa constrictor curled up in the corner can and does squeeze the life out of other animals. And decide to release them so that we can all deal with them. But these animals are nothing compared to other non native species that invade the North American continent every single day. YES, EVERY SINGLE DAY.  And, I am talking here about the seaborne animals that get dumped into the Great Lakes, and our harbors and our ports and our rivers when a commercial shipping vessel dumps the ballast that it picked up in another hemisphere. Nor the other VERY poisonous animals that come in with cargo like that huge, poisonous spider that was recently found with the bananas in a food store. This ill considered bill would do nothing for the Brown Tree Snake that decimated the island of Guam where the honorable congressional delegate comes from. But it does make provision to kill our so called “exotic” pets, which frankly are no longer exotic anymore as Leigh Ann says. They are, however, critically endangered and vulnerable. And as long as man continues to destroy and decimate their native environments, we are their last best hope for continued existence at all. This bill gets voted on April 23. PLEASE make your thoughts and comments known to your congressional representative. Visit  <a href=”www.capwiz.com/naiatrust/” target=”_blank”>Capwiz </a> and say not just NO but HELL NO! I am not even going to address HSUS or PETA. This bill has enough wrong with it that it does not need the addition of these two organizations. But, note well, that if this bill becomes law in any way, dogs and cats just became bigger targets on the horizon.