Eastern Spotted Newt (Notophthalmus viridescens) © Dave Huth
The announcement that US Fish and Wildlife Service (USFWS) would be placing movement restrictions on over 200 salamander species, including 67 US native species, has unsurprisingly resulted in much conversation across the community, from scientists to state wildlife officers, and pet keepers to NGO staff. As we enter the comment period on the Ruling we felt it would be helpful to look back at the recommendation made by the Amphibian Survival Alliance to the USFWS and see where we can go next.
As an Alliance, our primary interest in this issue has been reducing the global spread of Batrachochytrium salamandrivorans (Bsal) as much as possible. It is important to understand that as far as we know, the Bsal pathogen has only recently been found outside of Asia; evidence of its presence in Asia goes back over a century. It is true that strains of other amphibian chytrids are found throughout the world, and while some strains appear to have little impact on the health of amphibians, others have been responsible for driving populations to collapse and in some cases potentially leading to extinctions. Different strains can also have differing virulence, and hybridization of strains appears to be possible. We know that Bsal was only confirmed in Europe recently (in the last few years) and current evidence seems to support the theory that it has been brought out of Asia via the trade in salamanders.
So why are we only seeing Bsal now? There has been a trade in Asian salamanders for decades (in reality, probably even longer), so surely we would have seen this before? Well one possible reason for its recent appearance is that we are seeing new species on the market, so perhaps Bsal came from one of these species and was more recently introduced to the trade. It is also possible that Bsal might have been restricted to a very specific region in Asia, one where collections have only recently begun. However, this is all speculation. It is equally as feasible to assume that we are only now seeing this fungal pathogen because it has only just been introduced to the international market.
In Asia, where the species have evolved with Bsal, they have a natural tolerance to it. However, the same cannot be said for salamanders in other parts of the world. So far there is no evidence of Bsal occurring naturally outside of Asia, although this might change as more research is done but that is what we know now.
Some people have questioned whether Bsal can be tied to the trade in amphibians or herpetoculture. Here is what we know: There have been several studies looking at Bsal in both wild and captive populations, the most significant being by Martel et al in 2014, and we have included some references for those interested in reading the papers themselves. Some studies have sampled animals in transit or destined for the pet trade or private collections and although positive rates are generally low, infected animals in trade have been detected. It is important to note that even a low infection rate multiplied by a large number of imported individuals leads to infected individuals being imported. Quite simply, trade is a confirmed pathway for Bsal, at low prevalence, while widespread testing of wild populations outside of those impacted in the Netherlands and Belgium has yet to turn up any evidence of Bsal. Fortunately, the vast majority of people acknowledge this situation and are looking at positive ways of addressing the threat.
When the Alliance first submitted a letter to the USFWS requesting that they take action to prevent the spread of Bsal into the U.S. this was our understanding of the situation. We had a newly described fungal pathogen from Asia, that appeared to be moving into Europe from the trade in salamanders and causing significant die-off events. Our request to the USFWS was simple:
- Place an immediate temporary moratorium on the imports of all salamander species (the entire Order); and
- Have the lifting of the moratorium tied to the development and implementation of a verifiable clean trade program paid for by the importers.
From the luxury of our position (i.e. not having to implement this measure) we saw the best approach being one that maintained the ability to move amphibians around while ensuring that the risk of spreading disease was minimal. Our aim, like many others involved in this issue, was first and foremost, to prevent the spread of Bsal.
The support for the measures proposed by the Alliance was widespread, and it was clear that all those involved were willing to make sacrifices as long as they made sense. For example, let’s stop the import of salamanders from outside the US until we can screen these animals coming in. This would impact both research facilities and the trade but there was a general sense that it made the most sense because after all, no one wants to be responsible for this pathogen entering the wild in the world’s salamander hotspot.
Throughout the conversation it was clear that the focus should be on international trade not the movement of species within the US. After all the threat is coming from the international market and not from within the US. That said, we still need a plan for what to do if and/or when Bsal is detected in the US. Already a great team of experts are working on this strategy and more can be found out about this at salamanderfungus.org
We have actively been supporting the screening of Bsal for pet owners through our free testing kits program. The response by the hobbyist community has been incredibly supportive. Some hobbyists that had their salamander screened are now even offering their animals as “Bsal-free.”
With broad support for an international moratorium on the importation of all salamanders, in addition to the development of a clean trade program, how did we end up with the present Bsal interim ruling that includes restrictions on native US salamanders? A lot of this seems to come down to what USFWS has the authority and ability to implement, along with the evidence for such action. The evidence pointed to certain species, and they considered risk to be highest among those most closely related, i.e., those species within the same genus as any other species documented to be able to carry Bsal zoospores. However, in its current state, the interim rule does not provide for evidence of no risk, e.g., testing of animals in transit meeting criteria to be considered disease-free, to be allowed to continue in transit.
Dating back to 1900, the Lacey Act was the first federal wildlife conservation bill passed in the US. The “injurious wildlife” provisions of the Act are set up to address threats to wildlife by individual animal species. Since it was created, the Lacey Act has been used to address other threats to wildlife that no other Act can address. Unfortunately, this means continued pressure on the Lacey Act and the potential for political action that falls short of what might be really needed. As a result, the Alliance, in partnership with other conservation groups, is exploring the concept of a new wildlife health bill, separate from the Lacey Act, but allowing state and federal agencies to respond to issues such as Bsal in an effective and rapid manner. We hope that the product coming out of this effort will support business and conservation effort simultaneously, and help to effectively limit the number of wildlife pathogens we are having to address in an ad-hoc manner.
But back to the current situation. Scientifically speaking, the justification for the interim ruling is logical, but it does create what might be perceived as practical hassles. From a research perspective, the requirements under the interim rule are not all that different from those under the Migratory Bird Treaty Act (MBTA) which requires permits for a range of activities related to birds. It’s clear that the interim rule will impact a range of research activities and the potential consequences of these are being communicated to the Service through various groups and individuals.
The reality, however, is that we all have an opportunity here to be involved in this rule-making process. The USFWS has made it clear that they wish to hear comments regarding the interim rule, and from our view point are genuinely interested in finding the best solution to the problem. In fact, they ask 14 specific questions that want input on. The rule goes into effect on January 28, 2016, but will not be considered final until after comments are received and addressed.
So we encourage you to use this comment period to articulate your concerns to the USFWS, and more importantly, to offer suggestions on how to address your concerns. If you have any questions, please let us know and we will address them as quickly as possible.
For those interested in learning more about the current Rule there will be several Q&A conference calls before comments are due to help address concerns and answer questions. FWS officials from both rulemaking and permitting will be on the line on each call. We will provide more information on the calls as soon as we have the details. Until then, we encourage all those who have not had a chance to do so to visit http://www.regulations.gov/#!docketDetail;D=FWS-HQ-FAC-2015-0005 to read information on the Rule and make comments directly to the USFWS.
On Thursday, January 28, 2016 at 1:00PM EST is the first of three Q&A webinars sponsored by Partners in Amphibian and Reptile Conservation and the Association of Fish and Wildlife Agencies to address a) the recent U.S. Fish and Wildlife Service rulemaking listing salamanders as injurious in the Lacey Act, b) potential impacts to existing research and conservation efforts from the rulemaking, and c) permitting requirements, and compliance. Two or more USFWS representatives from the branches involved in the rulemaking and in the permitting, or law enforcemement, will be on the line to answer questions directly. Register for this webinar HERE.
In closing we want to acknowledge the hard work the USFWS staff put into to developing this Rule. Clearly there are many questions from various stakeholders but nonetheless the Service responded as requested by a large number of people and organizations in taking action to prevent the spread of Bsal into North America, and for that we thank them.
- Martel, a., Blooi, M., Fisher, M. C., Farrer, R. a., Schmidt, B. R., Tobler, U., … Pasmans, F. (2014). Recent introduction of a chytrid fungus endangers Western Palearctic salamanders. Science, 630, 34–36. http://doi.org/10.1126/science.1258268
- Cunningham, A. a., Beckmann, K., Perkins, M., Fitzpatrick, L., Cromie, R., Redbond, J., … Fisher, M. C. (2015). Emerging disease in UK amphibians. Veterinary Record, 176(18), 468–468. http://doi.org/10.1136/vr.h2264
- Bletz, M., Perl, R. G. B., Schmeller, D. S., Mutschmann, F., Sabino-Pinto, J., Wagner, N., … Hendrix, R. (2015). First detection of the emerging fungal pathogen Batrachochytrium salamandrivoransin Germany. Amphibia-Reptilia, (January 2016). http://doi.org/10.1163/15685381-00003008