3. Global Wildlife Conservation
The Biodiversity Group
Conservation International
Center for Biological Diversity
Defenders of Wildlife
Fauna & Flora International
Roger Tory Peterson Institute of Natural
History
International Society for the Study and
Conservation of Amphibians
Meet Your Neighbours
Detroit Zoological Society
Herpetological League
Insituexsitu
Amphibiaweb
Amphibian Ark
Conserve It Forward
Wildlife Conservation Society
Inaturalist
The Wandering Herpetologist
And many other groups……
Call for action
Letters sent to USFWS
TX 78767 USA
www.amphibians.org
Page 1
November 17, 2014
Dan Ashe, Director
U.S. Fish and Wildlife Service
Department of the Interior
1849 C St NW
Washington, DC 20240
Re: Urgent request to protect native salamanders
Dear Director Ashe,
This is an urgent request on behalf of the Amphibian Survival Alliance (ASA) and the undersigned partners for
you to protect America’s salamanders by taking action against a well-documented emerging and deadly wildlife
disease, Batrachochytrium salamandrivorans (or Bsal), which so far has not arrived in the USA.
As the world’s largest partnership dedicated to amphibian conservation, the ASA is supported by many of the
world’s leading conservation organizations and research institutions. This network positions us uniquely to help
advise on the implementation of a broad range of conservation strategies, and we offer our assistance to the
Service in helping to address the significant issue.
We ask you to use every possible authority to achieve this, with particular focus on the Lacey Act and the
Endangered Species Act (ESA). We note that the ESA Sec. 7(a)(1) directs: “The Secretary [of the Interior] shall
review other programs administered by him and utilize such programs in furtherance of the purposes of this
Act.” Your agency administers the wildlife import inspection and compliance programs at the nation’s ports of
entry. Through these programs the Secretary of the Interior exercises authority over imports of all live
salamanders. In view of this major new import-related threat to the many ESA-listed Threatened and
Endangered salamander species, we urge you to manage these programs to ensure that Bsal and other diseases
are kept out of the nation.
We recommend that your agency promptly suspend all imports of any salamander or newt. Then, promptly
develop a program of only allowing imports that are certified by the Service as free of Batrachochytrium
salamandrivorans and other deadly salamander pathogens or parasites. Such certification could be based on
verified clean sources, reliable testing, treatment, quarantine or other measures; the precise approach will require
expert design and review. The number of animal import businesses that deal in salamanders is small; they
should be supportive of measures that ensure their shipments are certified to not carry a potentially devastating
disease.
ne avenue to achieve a more comprehensive amphibian disease prevention approach could be by the Service
positively to the Defenders of Wildlife 2009 Petition: “To List All Live Amphibians in Trade as
e of Batrachochytrium dendrobatidis,” The Service has already taken public comment on
response would need to be broader than the scope of that Petition. The Service
4. The Ask
The focus of the request to USFWS has been the implementation of
a clean trade program including an Order-wide moratorium on
the importation of salamanders until such time as an effective
screening program can be implemented.
5. Lacey Act
The Lacey Act addresses illegal wildlife trade to protect species at risk
and bars importing species found to be injurious to the United States.
Today it regulates
the import of any
species protected
by international or
domestic law and
prevents the spread
of invasive, or non-
native, species.
7. The Trade
• Salamanders represented 5.5% of the amphibians imported into the USA
• 95% of imports belong to Cynops, Paramesotriton, Salamandra, and
Tylototriton.
• All contain at least one species known to be susceptible to Bsal
• Cynops and Paramesotriton comprise >90% of U.S. imported salamanders,
hence these genera may be the greatest threat.
Gray et al. unpublished
8. Policy Overview
- Concerted attention brought to USFWS officials
- Agency wants to act but there are challenges
- Rulemaking soon? Expect delays
- The Big Question - Will the scope/coverage be broad enough to work?
9. Advocacy
- Continued pressure on the Administration to act
- If no Proposed Rule by 9/15 target date, ramp
up the advocacy
- Join Bsal Team coordinating email list if you can
engage in concerted advocacy:
contact: jenkinsbiopolicy@gmail.com
11. Further support
“A moratorium on importation of Bsal-
susceptible salamanders should be put into
place until such time as effective testing and
treatment regimens have been developed,”
Robert Likins, the PIJAC’s council’s director of
governmental affairs, wrote in an email.
Unusual trade regulation case with Bsal, because strong
support from regulated industry: (NY Times, 7/30/15)
12. Review of Policy Actions
Longer term:
- Whether amphibians, bats, snakes,
birds or other groups, the national
wildlife health protections are
completely inadequate.
- We must get new law passed for faster
and more comprehensive response to
the next wildlife pathogen crisis.
- We have good model in the USDA
health protection laws for farm animals.
- We are working on it: funding is
needed to pass new law
13. In Canada
The Canadian government is actively
working to reduce the risk of Bsal
introduction through import control
Environment Canada is exploring
emergency measures
The Canadian Wildlife Health Cooperative
leading national surveillance and
education
14. In Mexico
Scientists in Mexico and the USA are
collaborating with laboratory experiments
to test the susceptibility of their native
salamander species to Bsal