The North Carolina Wildlife Resources Commission (NCWRC) has proposed new rules regarding keeping and importing (into North Carolina) reptiles and other animals. The biggest issues for herpetoculture in this proposal are a ban on all tegus and import permit requirement for native herp species. There are also changes to the native turtle species regulation.
There will be one Virtual/Zoom hearing (all in-person meetings have been canceled):
Date: January 20, 2022
Time: 7:00 p.m.
Location: Register Online at Webinar Registration - Zoom Webinar ID 160
983 2165 US: +1 669 254 5252 or 833 568 8864 (Toll Free)
The comment deadline is January 31, 2022. The hearing dates/locations and comment submission details are below. If you have issues with or oppose any of these proposals, you must contact NCWRC and speak at the hearings for there to be any possibility of stopping overreach and unintended consequences. Remember to be civil and professional at all times!
Full NCWRC proposal: https://usark.org/wp-content/uploads/2021/12/NC-regs-2022.pdf
NCWRC Regulation/Rule Process: https://usark.org/wp-content/uploads/2021/12/NCWRC-Rules-Process.pdf
Here is a brief summary:
- IMPORTATION OF WILD ANIMALS AND BIRDS (15A NCAC 10B .0101 I) pages 3-4: Currently, NCWRC requires an import before bringing (importing) any ” live wild bird or wild animal” into North Carolina. NCWRC has proposed to amend this rule to read “live wild bird, wild animal, or any native reptile or amphibian.” Some native species are common in herpetoculture and have been bred under human care for decades (i.e. corn snakes). The rule name will change from IMPORTATION OF WILD ANIMALS AND BIRDS to IMPORTATION OF WILD ANIMALS, BIRDS, AND NATIVE REPTILES AND AMPHIBIANS. NCWRC has this definition for wild animals: Game animals; furbearing animals; feral swine; and all other wild mammals except marine mammals found in coastal fishing waters. In addition, this definition includes members of the following groups which are on the federal list of endangered or threatened species: wild amphibians, wild reptiles except sea turtles inhabiting and depending upon coastal fishing waters, and wild invertebrates… Wild birds: Migratory game birds; upland game birds; and all undomesticated feathered vertebrates.
- LIMITATIONS ON CERTAIN EXOTIC SPECIES (15A NCAC 10B .0123) pages 6-7: These species will be listed as prohibited: Tegu (genera Salvator and Tupinambis ) and Greenhouse Frog (Eleutherodactlyus planirostris). Persons with those species prior to August 1, 2022, may “retain, transport, transfer, or export” those animals that were previously held but future acquisitions, breeding, and sales would be illegal.
- COMMERCIAL TAKE OF CERTAIN TURTLES PROHIBITED (15A NCAC 10H .1301) page 39: A change to the current native turtle sales prohibition has been proposed. The current rule will be replaced with this text, “Buying or selling any native turtle species is prohibited except for snapping turtles (Chelydra serpentina) with a curved carapace length of 13 inches or greater as authorized by 15A NCAC 10B .0119.” The rule name will change from COMMERCIAL TAKE OF CERTAIN TURTLES PROHIBITED to SALE OF NATIVE TURTLES. Currently, commercial taking is illegal for many native turtle species. “Commercial taking” is defined as the taking, possession, collection, transportation, purchase or sale of five or more individuals. This currently includes 11 species and 1 subspecies (all native species in the families Emydidae and Trionychidae). The new rule would expand this prohibition to all native species. Also, currently, a scientific collection license is required to collect more than four turtles.
- POSSESSION OF REPTILES AND AMPHIBIANS (15A NCAC 10H .1302 P) pages 39-40: This rule has some new language including “per physical address” and “Possession permits are required for the rehabilitation of native reptiles and amphibians.”
- WILDLIFE COLLECTORS (15A NCAC 10B .0119) pages 5-6: Changes to the Wildlife Collection License.
Public Hearings
There will be three in-person hearings (CANCELED) :
There will be one Virtual/Zoom hearing:
Date: January 20, 2022
Time: 7:00 p.m.
Location: Register Online at Webinar Registration - Zoom Webinar ID 160
983 2165 US: +1 669 254 5252 or 833 568 8864 (Toll Free)
Where to submit comments
Comments submitted by mail: Rulemaking Coordinator, 1701 Mail Service Center, Raleigh, NC 27699
email: regulations@ncwildlife.org
Talking Points
These can be used in your comments. Please edit and personalize.
- If NCWRC must regulate tegus, there must be a common-sense approach allowing responsible keepers and breeders continued trade activities.
- Reptile enthusiasts want to protect our State’s environment while working with NCWRC on non-native species issues to protect our rights.
- Tegus can be bred and sold in North Carolina while still protecting the State’s environment.
- Responsible herpetoculturists can certainly keep this species without harming North Carolina’s wildlife and environment.
- Irresponsible persons should be punished but a ban that does not consider current tegu breeders is overreaching and unjust.
- Responsible herpetoculturists want to address problems but NCWRC should realize that we responsible keepers are not the problem.
- A ban without common-sense exemptions and permits will create additional issues, such as creating an underground black market or causing additional releases.
- Current, responsible breeders should be allowed to continue if they have proper caging that prevents escapes.
- NCWRC’s proposal to require importation permits for state native reptiles and amphibians seems draconian and arbitrary.
- Some native species, like the corn snake, have been bred by herpetoculturists for several decades. The animals found in trade are bred under human care and not collected from the wild.
- Many good people will be violating the law as they will be unaware that they need an import permit to buy an albino corn snake from a breeder/seller in another state. Why would someone think they needed a permit to buy a pet corn snake?
- Corn snakes and some other state native herps are common pets but those buying these animals are buying animals bred under human care and not collected from the wild.
- If NCWRC can show that this import permit requirement is critical to protect wild animals, then there should be exceptions for certain species including snakes 1. under a certain length, morphs (animals not displaying wild phenotypes), animals that have been born under human care, etc.
- Any importation permit should be easy to attain and not buried under oppressive paperwork and hoops to jump through.
- There are literally tens of thousands of corn snakes kept as pets in the U.S. With at least five million households keeping pet reptiles and corn snakes being in the top ten commonly kept species for decades, it is easy to see why this importation permit requirement could cause issues, and this is just one species found in trade that would be included.
- Regarding the changes to 15A NCAC 10H .1301 and native turtle sales, there should be exemptions for those breeding native species who are not taking animals from the wild.
- Captive breeding of native species has been shown to actually reduce stressors upon native populations. Even the United States Fish and Wildlife Service has stated this publicly.
- Breeders and farms producing native turtles have been shown to have benefits for wild populations rather than harms.
- The United States Fish and Wildlife Service has recognized that turtle breeding/farming can alleviate the harvest of wild animals and provides a means to serve international markets without affecting wild populations.
- State-authorized breeding/farming operations using captive broodstock or otherwise legally acquired turtles should be allowed and excepted.
Sample letter
Remember to be civil and professional! Please edit/personalize your letters. This is just a sample.
NCWRC Commissioners and Staff,
I write today as a North Carolina resident opposing certain proposed rule changes to Title 15A regarding reptiles and amphibians (AKA herps). I am concerned with my state’s native animals and environment but I cannot support overreaching measures that infringe upon my rights as a responsible citizen and animal owner.
I oppose the proposed ban listing the species of Salvator and Tupinambis, known as tegus, as prohibited under 15A NCAC 10B .0123. I fully support protecting our North Carolina natural resources and wildlife but this ban is not necessary to accomplish that. Instead, protecting our state’s environment can easily be accomplished through sensible regulation and I do not feel this is a sensible proposal. There is currently no evidence of tegus breeding or surviving the climate long-term in this state. I am for regulations that make sense and protect our environment without jeopardizing the ownership rights of citizens of this state.
Responsible herpetoculturists have never been the problem in this state. Therefore, there is no reason to stop the ownership, trade, and commercialization of tegus. If NCWRC can show through peer-reviewed science that there is a legitimate risk for tegus to become established in North Carolina, then there are better alternatives than a ban. For example, PIT tagging and/or permitting can create more responsibility and liability on the owners of tegus. If an animal is released or has escaped, you now have an individual on record to hold responsible and penalize. This will hold the negligent owners accountable without punishing the responsible ones. This ban will cause more harm than good. For example, some will sell them illegally, which as a result, fuels a black-market underground trade.
Ultimately, it is not fair to completely end the trade of a species when there may not be supporting science and when common-sense alternatives are applicable. PIT tagging and permitting, while still allowing the trade of this animal, would fix the potential problem. Tegus are easily trapped so the odd escape or release, which will be curtailed or ended through common-sense ownership and sales regulation, does not pose a severe risk to our native fauna.
While the current proposed language does consider those people currently keeping pet tegus and allows those animals to be grandfathered, it does nothing to consider current breeders and businesses. Some businesses/breeders will have extensive losses if this passes without additional language. Since the new regulation provides for no restitution to businesses that will suffer substantial financial loss, I do not see how NCWRC can present this regulation without their consideration. Current businesses and breeders, which is only a small handful in our state, that can demonstrate their ability to prevent escape should be allowed to be grandfathered, also. If not, this is a rather unjust and unfair regulation.
Regarding the expanded ban on buying and selling native turtles, there should be exemptions for those breeding native species who are not taking animals from the wild, along with exemptions for buying turtles bred under human care. Captive breeding of native species has been shown to actually reduce stressors upon native populations. Even the United States Fish and Wildlife Service has recognized that turtle breeding/farming can alleviate the harvest of wild animals and provides a means to serve international markets without affecting wild populations. Breeders and farms producing native turtles have been shown to have benefits for wild populations rather than harms. State-authorized breeding/farming operations using captive broodstock or otherwise legally acquired turtles should be allowed and excepted.
NCWRC’s proposal to require importation permits for state native reptiles and amphibians seems draconian and arbitrary. Some native species, like the corn snake, have been bred by herpetoculturists for several decades. The animals found in trade are bred under human care and not collected from the wild. Many good people will be violating the law as they will be unaware that they need an import permit to buy an albino corn snake from a breeder/seller in another state. Why would someone think a permit was required to buy a pet corn snake?
Corn snakes and some other state native herps are common pets but those buying these animals are buying animals bred under human care and not collected from the wild. If NCWRC can show that this import permit requirement is critical to protect wild animals, then there should be exceptions for certain species including snakes under a certain length, morphs (animals not displaying wild phenotypes), animals that have been born under human care, etc. If this rule passes, any importation permit should be easy to attain and not buried under oppressive paperwork and hoops to jump through. There are literally tens of thousands of corn snakes kept as pets in the U.S. With at least five million households keeping pet reptiles and corn snakes being in the top ten most commonly kept species for decades, it is easy to see why this importation permit requirement could cause issues. And this is just one species found in trade that would require a permit.
I am asking that NCWRC work with responsible herpetoculturists to come up with better alternatives to these proposed regulations. We are willing to work with you and make sensible regulations. Thank you for taking the time to read this email and I look forward to speaking with you further. Have a good day.
Thank you,
YOUR NAME