Venomous Reptiles and Rule Change
The State of Florida has a long and storied history with captive venomous reptiles going back almost a century with famed herpetologists Ross Allen and Bill Haast. But in the wake of two high profile venomous snake escapes, Florida Fish and Wildlife Conservation Commission (FWC) has come under increased political pressure to tighten up venomous reptile regulations in the name of “public safety.” A new proposed rule is in the works, and there will likely be significant changes in regulation for zoos, venom labs and private keepers alike. FWC is currently accepting input from stakeholders through an online survey at www.surveymonkey.com/r/VR-Rule. Deadline for the surveys is July 27, 2016. There is also an opportunity to make public comment directly to FWC.
FWC has created a venomous reptiles working group known as the Venomous Reptiles Technical Assistance Group (VRTAG) to solicit stake holder input as a part of the process of formulating a draft proposed rule. FWC has a history of using TAG groups when seeking subject matter expertise on a given issue. I was selected as a resource to the VRTAG by FWC to represent clients in the zoo sector on behalf of Vitello Consulting. VRTAG meetings were held in early June and again in early July. Although the working group meetings were well run and allowed for an open exchange of ideas, there were clear lines of disagreement between FWC staff and the majority of VRTAG members.
The biggest point of contention between VRTAG members and FWC staff centered on a proposed three tier system of classification for venomous reptiles, with Tier I reptiles being unavailable for possession by private keepers that don’t meet the definition of “commercial” — such as dealers, zoos or venom labs. There could also be an increase in documented hours and/or educational requirements for venomous reptile license applications. Focus would be on incrementally moving up the tier system over time like building blocks — i.e., with Tier III being a prerequisite for Tier II, and Tier II a prerequisite for Tier I. Additionally, a proposed rule would likely require secondary containment for all three tiers, with tertiary “lockout doors,” specially constructed “out buildings,” and “pit tag” identification for Tier I reptiles.
Aside from the online survey that is being conducted by FWC, it is imperative that anyone who has an interest in venomous reptiles in Florida to make a substantive public comment. This is not just an up or down vote. If you want your public comment to carry weight, you must submit “substantive” public comment. That is a comment that specifically addresses concerns about the current draft of the proposed rule, or suggests alternatives to provisions of the draft. Being generally for or against the draft rule will not carry much weight.
Make Public Comment to FWC regarding Venomous Reptiles and the VRTAG!
Please make public comments here: MyFWC.com/wildlifehabitats/captive-wildlife/recommendations/
Below are all of the current documents forming the basis for a draft proposed rule. Provisions of the draft rule will likely change at least somewhat. I should have an updated draft sometime in September. I will post an update as soon as possible.
- Draft Tiers with Quantified Values
- 68A-6.001 Definitions
- 68A-6.007 Possession
- 68A-6.0071 Record Keeping
- 68A-6.0072 Identification
Andrew Wyatt is a government affairs and policy consultant that works exclusively in the wildlife sector.
“Venomous Reptiles and other wildlife issues are highly charged and contentious. I specialize in working with clients to employ campaign style tactics to change hearts and minds on vital wildlife issues. Please follow The Last Word on Wildlife for insight and analysis particular to the 21st century wildlife sector. If you would like to discuss the potential advantages of running a targeted issue campaign, and/or a comprehensive government affairs strategy, please call or email me.” ~ Andrew Wyatt
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