Esther Raposo
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Tags: marketing
Arnoldo Glauert
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Do you love your snakes but hate writing? Do you find yourself staring at the comment form on the government webpage trying to think of something intelligent to say in order to save your pets? Do you want to do better than the typical shallow tweet or emoticon-filled Facebook comment that defines so much of communication these days? Do you feel shamed because you haven’t commented but secretly wish for the comment period to pass so that you no longer feel pressured to do something? Do you sit there staring at the computer waiting for words to come? 

I like writing, and some people even say that I’m good at writing. Even so, I’ve struggled with these kinds of feelings and frustrations as I’ve thought about the new comment period for the constrictor rule. I want to get everything perfect because I want to make the comment that will somehow swing the tide in our favor. I wonder whether something I could say would make the difference. I read the talking points and want to use them most effectively, but I don’t want my letter to be just another form letter that someone on the other end will dismiss. I ended up writing a letter that wasn’t great, but I acted because I was afraid other pressures would cause me to miss the deadline. 

I have some experience in politics and in writing. My ideas won’t help everyone, but maybe I can make writing these letters a little easier for someone. If you don’t like my advice, that’s fine. If you can use something, I’m happy to help. 

Step 1 – Just like school

If you are beyond a certain age, you had teachers who wanted you to outline a paper before you wrote. The outline was another painful part of the painful process of writing. You told yourself that once you escaped school, you’d never outline anything again. For now, let’s try outlining again. Ask yourself what are the most important three points that you want to communicate about the constrictor rule. Write your answers. They may look like this: 

1. These animals won’t live outside Florida. 

2. They aren’t really dangerous.

3. The interstate transport restriction isn’t fair.  

These three points will be the body of your letter. You’ll have a short, polite paragraph at the front of your letter saying that you oppose the ban/addition of more snakes to the Lacey Act. You’ll have a shorter paragraph at the end repeating that you oppose adding these snakes to the injurious species list. You’ll turn each of these points into a paragraph. That’s all you need to do. 

Another of those writing rules in school was that every paragraph should have a thesis sentence and that the thesis sentence should be the first sentence. After that thesis sentence, everything in the paragraph should support the thesis sentence. Generally, that’s a good way to write anything formal. Because I’ve tried to make this commentary less formal, I haven’t followed that rule. Even my letter to USFWS didn’t follow that rule as well as I would have liked. Don’t worry about slight deviations. 

One more point is that all of this will be easier if you write your letter in a word processing program and then paste the text into the comment section of the website. 

Step 2 – Flesh out your ideas

The next step in the process is to put together the supporting facts for each of your main points. I still suggest the outline format to get a better feel for what you want to say. Figure out which evidence best supports the three points that you want to make, and write those pieces of evidence under each point. 

You need to remember your audience. The readers will often be regular folks who just happen to work for the government. They go to work every day, put in their hours, earn their paycheck, and go home to their lives. Some of them have opinions on these topics, and others think the whole thing is a waste of time. They may want to do a good job catching all of the facts and feelings in these letters, but they aren’t experts at sifting through every word to find some tiny jewel of information. Unless you have some high level of expertise or research data in this field, you probably don’t need or want to go over the character limit. They won’t be impressed by the bravado that makes you think that you’re the center of attention when you enter a room. You need to be clear, concise, and polite.

For each of your points, write the supporting evidence that you want to present. For now, write them as bullet points. 

1. These animals won’t live outside Florida.

  • The escapees after Hurricane Andrew have been there for over 20 years and haven’t expanded northward. 
  • Not every snake that irresponsible owners have dumped in the wild was dumped near the Everglades, but no other breeding colonies exist outside three counties down there. 
  • Experiments done around the time of the first comment period showed that Burms don’t have a hibernation instinct. 
  • Freezes in Florida killed many Burms and boas. 
  • Incubating retic eggs in a specialized incubator is hard enough. They won’t survive cold fronts and cold rains in the US. 

2. They aren’t really dangerous. 

  • The only US retic deaths were from sick snakes being treated. 
  • No one outside a keeper’s home has ever been killed by one of these snakes in the US.
  • They can’t and don’t chase people. 

3. The interstate transport restriction isn’t fair. 

  • This restriction will force people to give up family pets or face breaking the law.
  • This restriction will harm those who raise these animals as a home business. 
  • This restriction doesn’t protect people or the environment – see first two points
  • People transport plenty of other animals that are more hazardous. 

Step 3 – Write paragraphs

This step is simple once you’ve done the preparation work. Even if your writing isn’t eloquent, the organization of your thoughts means that the reader will understand your points. In this case, I’ll throw together these paragraphs. 

“The most important reason why USFWS should not add more species to the constrictor rule is that these animals cannot live outside extreme southern Florida. The original Burmese pythons in the Everglades escaped a warehouse during Hurricane Andrew in 1991, and they haven’t expanded northward in over twenty years. Not every irresponsible owner who releases a python will drive all the way to the Everglades, but no feral breeding populations exist anywhere else.  Experiments done in South Carolina about four years ago show that these animals don’t develop a hibernation instinct, and the deaths of boa constrictors and Burmese pythons in the 2010 freezes emphasize this point. Aside from the challenges of surviving a winter, many of these animals would be unable to incubate eggs any further north.” 

“While the USFWS mission is about protection of our national resources and not about public safety, these animals are not dangerous to the general public. No one outside a keeper’s home has ever been killed by one of these animals in the US. The only deaths in the US by reticulated pythons have resulted from someone trying to administer veterinary treatment while alone. These animals have no instinct to chase people for any reason and aren’t fast enough to do so.” 

“The interstate transport restriction isn’t fair, particularly considering that this restriction does nothing to further the USFWS mission of protecting our natural resources. Many people have reticulated pythons, boa constrictors, or anacondas as beloved family pets, and in our mobile society, people have to move. This rule would force people to give up these pets. Others are making extra money as hobbyist breeders, and the restrictions would hurt their sales. To do this harm with no benefit to the USFWS mission is unfair. The injustice is even worse because so many other animals that are higher risk can still move freely.” 

Step 4 – Write the introductory paragraph 

The introductory paragraph really doesn’t need to say anything besides the fact that you oppose putting any more species on the injurious species list of the Lacey Act. Some kind of polite “thank you for listening” sentence might help also. Otherwise, I have only a few thoughts. 

I mentioned in my letter that putting Burms, Afrocs, and yellow anacondas on the list was a mistake. I’m still not sure whether I like this strategy. I like the idea of trying to plant the seeds for a reversal of the rule. On the other hand, some might see those kinds of comments as starting the letter with a complaint. 

If you have specific qualifications that might impress the government, mentioning them could be worthwhile. No one in government really cares whether you were the first breeder to hatch some morph combination, so don’t go there. The two qualifications that are most important are education in related fields and military service. If you have a bachelor’s degree or higher in biology, zoology, biochemistry, or a similar field, you should mention that accomplishment. (If you have a PhD in that kind of field, you certainly want to sign your letter as “Dr. whomever,” but if you have a PhD, you shouldn’t need my advice on writing.) Vocational training as a vet tech is also worth mentioning. Military service doesn’t make you an animal expert, but people in government rightly value anyone who has served and will give a little more credence to that letter. 

One of the tricky issues is whether to mention anything political. Officially, the whole decision should be above politics, but in reality, politics plays a part. Ever since the HR 669 fight of 2009, most of the DC politicians against us have been Democrats and most of our allies have been Republicans. I know that the reptile community is about evenly split politically, and I’m not trying to start a political discussion. Some of the bureaucrats in USFWS have been there for years and served under both parties. Others are going to represent the administration in power. If you were a volunteer for Obama, maybe there is some advantage to saying that when you worked so hard to get him elected, you never expected his Interior Department to ban your pets. If you just voted for Obama but didn’t do any real volunteer work, I don’t see much value to saying anything. If you are a Republican, mentioning politics would be a bad idea. 

Once you’ve thought about this stuff, write your introductory paragraph. 

“Dear USFWS: 

Thank you for the opportunity to comment on the possible inclusion of additional constrictor species to the injurious species list of the Lacey Act. Please count me as a US citizen who opposes the addition of these species. Specifically, I oppose adding the reticulated python, the boa constrictor, or any anaconda species to the injurious species list. I’ll give my reasons here.” 

Step 5 – Write a closing statement

A one or two sentence “paragraph” is fine as a closing paragraph. 

“Thank you again for the opportunity to voice my opinion on this issue that I find vitally important. Please count me as opposed to listing additional constrictor species on the Lacey Act.” 

Step 6 – Copy and Paste the letter together

All of us know how to copy and paste paragraphs. Once you put together the entire letter, run a spell check and a grammar check. Microsoft Word will make a big deal of “passive voice.” Don’t worry about that. Sometimes, the grammar check will call something a sentence fragment when the sentence is fine. You should worry more about noun and verb agreement and basic spelling. 

Step 7 – Paste the letter on the website 

Our real strength will be in numbers. If you do a good enough job, that’s all we can do. Don’t worry about things being perfect. 

My comment to USFWS
Posted July 16, 2014 by wftright

Dear USFWS: 

Thank you for the opportunity to comment again on the constrictor rule and possible inclusion of five more species on the injurious species list of the Lacey Act. Information that has come to light in the past four years should lead to the removal of the original four species from the injurious list  and should certainly preclude the addition of these five species. 

The original rule was based on a paper published by the US Geological Survey. That paper looked at the natural ranges of one species and tried to predict where that species might be able to spread in the United States. That paper used a limited number of parameters in its model, and this methodology produced deeply flawed results. The methodology did not predict the natural Asian range of the Burmese python and should never have been used to extrapolate to possible ranges in the United States. In the intervening years, better models using more parameters have shown a better correlation with Burmese pythons’ natural range and also show that Burmese pythons cannot survive in the United States outside the southernmost tip of Florida. This finding is further supported by the fact that Burmese pythons have moved no further north and are surviving only tenuously in southern Florida. 

Since the time of the first comment period, the government has tried to hold a major hunt of Burmese pythons, and the result was that very few pythons were found. Proponents of the ban expected a huge number of snakes to be caught to show that they have become abundant. Instead, the small number of captured snakes is evidence that they are not taking over the Everglades. 

With all of the evidence showing that the first extrapolation from the Reed and Rodda paper was flawed, the case for adding additional species to the list is completely baseless. We have no evidence related to reticulated pythons, and while many reticulated pythons like to swim, they are not water-dwellers. Anacondas live much of their lives in water, but nothing suggests that they could live in the United States. A small colony of boa constrictors seems to survive in extreme southern Florida, but they show no signs of moving north. Boa constrictors native to Central Mexico have had thousands of years to move north, and they haven’t. The evidence suggests that boa constrictors have reached their natural limits. 

Proponents of the original listing cited global warming as a reason why these animals may find expanded ranges. Over the past four years, we’ve seen the global warming terminology changed to “climate change.” Many remain skeptical of either global warming or climate change, and non-skeptics argue that climate change is the more accurate term because the effects can produce greater extremes in both heat and cold. They say that the changes in our weather patterns can lead to harsher winters even while producing warming trends and loss of ice at the poles. If the climate isn’t really warming, then warming cannot be part of expanding range. If climate change is producing greater extremes, then climate change will likely destroy feral constrictors in the United States. These snakes simply don’t adapt to extremes. 

Over the past four years, the reticulated python market in the United States has grown. Breeders have adapted to the public’s desire for smaller snakes that are easier to feed and clean by offering island varieties that remain small. These snakes are popular for their beauty and intelligence but require less space to keep and less money to feed. They are excellent pet citizens and like their larger cousins have lower impact on the environment than more traditional pets. Just as large dogs can be great pets but aren’t practical for everyone, larger reticulated pythons are great pets but aren’t practical for everyone. Adding any reticulated pythons to the list would harm the people who have come to love these wonderful animals as pets.  

Another major event of the past four years is the resolution of a court case involving the Humane Society of the United States, one of the primary proponents of adding these snakes to the injurious species list. This organization was sued over false statements made in an effort to destroy a business and eventually had to settle because they would have lost. They and their activists lied in an effort to force their agenda, and as you consider comments that will be made in favor of the ban, please remember that their reputation for false statements has only grown over the past four years. 

Please do not add any snake species to the injurious species list of the Lacey Act. Instead, a better policy would be to consider removing the species added in 2012. 


William Kelly

Posted June 30, 2014 by hillbilly127

What does it mean when my female chinese water dragon lays on my male??

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