State pushes to tighten wild reptile collection rules-Nevada

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WSTREPS
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by WSTREPS »

The reason I gave credence to the quotes is two fold. First, the various quotes attributed to Jason Jones are from a several journalist and all such quotes are very similar in content. Secondly, quotes attributed to Jason Jones dovetail with the information contained in his power point document.

Richard F. Hoyer
That is correct, What was printed in the press is just what Jason Jones said. There are no excuses. I heard every word NDOW biologist Jason Jones said during his presentation and carefully listen to the questions and responses. How I characterized Jones is who he is. Notice how the Jones fanboy club steers clear of the major points of contention found in both his presentation and press, they focus on personal attacks but can not defend or explain away the blatant and intentional misrepresentation, the off topic sensationalism and complete lack of science found in all of Jason Jones content. All the facts that were strategically left out. The nearly complete lack of science. This was a kangaroo court from the git. Following a form and strategy that masquerades as science but is really career driven activism and government overreach. The bigger problem in all this. Is that this type of government overreach and legal bulling is not just an artifact of trivialities, such as catching a couple lizards in the desert. It has become more and more common place thru out society affecting bigger issues. I am not the least bit surprised at the short slightness and stupidity displayed by the people that support this type of corrupt government action or its flunky henchmen that pose as scientific authorities. Look at the silly games they have turned to in its defense. Displaying much more ignorance the knowledge. If this is what they will stoop to during the course of a minor debate on a lightly viewed internet forum.............hum.........................yeeeaaahhhh...........

Ernie Eison
Jimi
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Jimi »

Richard, I said I'd get back to you if you had questions. You had some re: NatureServe. To save myself the time of composing it all again, I have dug up this old stuff I wrote here on FHF (2 threads; in one I was talking w/ you - I believe all the quotes below are yours). Recall, please, that the deal I offered you, was to respond to your questions if you would read what I offer. It appears you maintain many of the positions you held before, which is your prerogative, but it also appears you retain some of your former misapprehensions, which I tried to correct or at least contextualize in order for you to have a more nuanced understanding of certain things. I hope I get through with you this time around. OK, here goes:

From 7/18/2012

- NatureServe (NS) works in partnership with the Heritage Programs (HPs). NS is an NGO, and was spun off from TNC several decades ago. Most HP's are embedded in state agencies. [Added 9/25/2017 - most, about 2/3, are in state agencies. About 1/3 are at universities - this is the case in Oregon. ORBIC houses Oregon's Natural Heritage Program.]

- Both NS and the HPs use the NS Rank Calculator (http://www.natureserve.org/publications ... tor-v2.jsp), and data collected or compiled by the HPs (http://www.natureserve.org/visitLocal/).

- Ranks are calculated at the subnational (mostly, state) level by the individual HPs. Exactly how the individual HP uses the NS Rank Calculator is up to their discretion in an important way. All HPs will utilize all the occurrence data at their disposal (and they are always seeking more!). But that occurrence data is only used to calculate the Rarity part of the rank calculation. There are 2 other parts - Threats and Trends. Some HPs are very inclusive in terms of who (internal only? if not, which "outsiders"?) they ask to help them with the Threats and Trends parts of operating the Rank Calculator, which at the end of the operation spits out the subnational/state rank. Some HPs are not so inclusive. It makes a difference, IMO. "The wisdom of crowds" and all that.

- Ranks are calculated at the national and global levels by NatureServe. Using the same Rank Calculator as at the subnational level, NS uses species occurrence data submitted more-or-less regularly by the individual HPs (supposed to be annually but I know from experience it can go longer, up to 4-5 years in egregious cases). As I understand it - and I could be wrong - NS does not rely entirely on the HPs' threat and trend assessments - they also superimpose their own synthesis (which does make some sense after all). I do not know how inclusive NS is - same questions as above - is it internal-only, and if not, then who else is asked to participate?

- I believe that if a species only occurs in one state, NS just uses that state HP's ranking.

- It should be clear to all that there's an irrefutable cascade of delay, and in my opinion there's also one of subjectivity, between state rankings, national rankings, and global rankings. That is, G-ranks are by and large the "flakiest". This is not so much the case with narrow endemics - such as many - not all - the taxa in the 53-herps petition of July 2012. It's also wise to keep in mind that while an S-rank of "2" has the same definition across state lines, the processes leading to the different "2's" embody some heterogeneity, as discussed above with Threats and Trends.

From 6/6-8/2016


Richard -

I know a bit about global, national and state ranks and offer to share some of it here. First of all, it's important to understand that the ranks are outputs of something called the NatureServe Rank Calculator. It's just a macro-enabled spreadsheet that the user enters values into, and then pushes a button to get the rank.

The basic categories of stuff the calculator considers to derive its output are 1) rarity, 2) threats, and 3) trends (both long-term and short-term).

NatureServe produces global and national ranks. When applicable, they prefer to use data provided by member programs (typically called Natural Heritage Programs) - in the USA most of them are at the state level. There are also Navajo Nation and Tennessee Valley Authority programs. When I say "state level" I don't mean those programs are operated by state agencies - most are, but about 1/3 are not. That appears to be the case in Oregon - it seems to be a university thing there. Most non-agency state-level programs are operated by universities. Two states I have lived in, Colorado and Florida, have this situation. It is not infrequently the case that when a universirty runs a Heritage program, the state wildlife agency has little to do with the program.

So just to repeat - S ranks are not produced by NatureServe. They are produced by state-level programs, and reported to NatureServe by participating or member programs. Participating in the NatureServe network, that is.
Quote:
...I came away with the conclusion that EOs are based on locality sightings which may be clumped into groups the then call EOs..
Emphasis added 9/25/2017.
Yeah that's about right. It's a bit of an abstraction. There is some direction given for e.g. colonial animals - it would be silly to have 2 (or 200) observations of individual prairie dogs from the same town each get their own EO. The dog town is the EO. Same goes for, e.g., a pelican or tern nesting colony, a sea turtle nesting beach, etc. For solitary animals, conceptually, a spatial buffer is applied to the observation. More about that below, on "grid cells".
Quote:
Well, depending on the species, there can be little correlation between the number of locality sightings and the numerical abundance of species. So the use of EOs to assess the status of species is a terribly flawed practice, especially as it pertains to secretive species such as many species of herps. The concept likely has more merit when applied to plants
Emphasis added 9/25/2017
If you look more closely at the rank calculator you will note that there are 2 basic ways to handle that "rarity" criterion. One is abundance, one is extent of distribution. Very few species are evaluated on the basis of abundance, for the simple reason that such data do not exist for most species.

So let's take extent of distribution. In the calculator, species occupying points or polygons are evaluated based on how many 4 sq km grid cells have an EO (all or part of them) in them. Species occupying lines (e.g. stream organisms) are evaluated based on how many 1 sq km grid cells they occupy. If a species in Oregon occurred statewide, in every conceivable habitat, it would occupy about 63,700 of the larger grid cells. A species occupying 3 springs in the same small valley might occupy 1 or 2 or 3 grid cells.[/b]

Restricted range is a widely-accepted predictor of imperilment. So is low abundance, but to a much smaller extent, particularly if distribution is large. Take large carnivores as an example. They are naturally "rare", but by no means may they be assumed to be imperiled.

In the calculator, rarity commands most of the weight driving the output - 85% in the current version if I am not mistake. Threats and trends take up the rest. I quibble with this, I think threats and trends ought to get more weight. But this is inviting a distraction...just remember that threats and trends are also included. How they are included can be utterly subjective, or it can be strongly data-driven. But just as an example, take the lower 48 grizzly population. The long term trend is terrible - they've been extirpated from >95% of their former range. However the short-term (last 20 years) trends are excellent - their distribution and abundance (the latter well-known in this freak case) have at least tripled. This is the case because most of the serious threats to grizzlies have been sufficiently managed to allow births and survival to greatly outpace deaths.

The important thing to keep in mind, is that the ranks are simply an index of the relative degree of imperilment a species faces. Forget trying to define exactly what a 3 is - the important thing is, it's better than a 2 and worse than a 4. You don't make a decision about a particular course of action just based on the number - you need to look at the specifics of rarity, threats, and trends.[/b]
Quote:
And as is typical now of state wildlife agencies, neither NatureServe nor the ODFW have any evidence in support of that S-3 ranking for the Night Snake in Oregon.
Again, I would look to whose rank that is, and I would further request of them the rank calculator report showing what inputs they used. The easiest way to "uprank" that animal would be to add more legitimate dots to the map - ones not in already-recorded grid squares. This is an important contribution FHF members can make.
Quote:
I have now twice taken time to inform myself about NatureServe and their methods. To sum up my position, it amounts to junk science at it finest.
Emphasis added 9/25/2017.
I think this is a bit extreme and I hope I can convince you to take a broader view. Perhaps not in how ODFW is using the ranks to do whatever it is trying to do, but simply to recognize that the Rank Calculator outputs are actually a very helpful device to help overworked, understaffed managers look at the entirety of a flora and fauna (virtually all of which is data deficient), and quickly determine what they do not need to worry about for the moment, and what needs some attention. What kind of attention is a whole 'nother thing entirely.

In my case, when I see an S rank that implies imperilment, but I "know" from experience that it ain't so, the first thing I do is try to round up more "locality sightings" as you call them. I want to paint the entire presumed distribution of the animal in locality sightings, if possible one every few miles in all directions. I do not rush to call something imperiled when it's obviously a simple case of insufficient data. Others may behave differently...but it can be good to ask first, before assuming any motives.

In the case of an animal that is restricted in its distribution, I look to the threats. If there are obvious threats the first order of business is to go about trying to reduce them, preferably starting with the worst ones first. Typically, those manifest in habitat loss and degradation, or excessive mortality or insufficient recruitment. Note that these are drivers of distribution and abundance - exactly the things the rank calculator gives most weight to.

Finally, operators of the calculator can always do a manual override. If for example a species has a naturally small distribution, but there has been little or no discernible change in that distribution, and there are no credible existential threats that have not been managed, if the calculator spits out a "1" the operator can always manually assign a "2" or "3".

Anyway, I hope this is informative. I will close by suggesting that to demand virtual omniscience as a prerequisite to taking some sort of action, is a pretty specious argument. You're damned if you do and damned if you don't, so you might as well do something that seems about right - that's the position conscientious managers are in. The trick is in figuring out what "right" is, and not just grabbing at the first thing you see. Those who appear guilty of doing that need to be called out, starting with an approach that is more likely to have them engage constructively, rather than retreat to the bunker.

cheers,
Jimi

*************************************************************************

Added 9/25/2017: Hopefully this addresses many of your points. I think it does, you may feel differently. Anyway, if you look at the documentation for the Rank Calculator, or any NatureServe publication, you will see plenty of cited works. Many are from older NS works, or from NS employees, but nonetheless I really think it is extreme and misleading to call their material "unscientific". I find it repeatable, transparent, and adequately substantiated for careful, eyes-open usage.

I would further add that while wildlife management seeks to retain "science" as a core factor in decision-making, it also integrates human biases & preferences (and all that they entail) in that decision-making. I know you have a degree (B.S., 1955, right?) in Wildlife Management, but I do not know that you ever practiced it, particularly in an agency, particularly at a middle or senior level. Did you? One gets quite an education in "the real world", with promotion. People really are the most interesting animal...
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WSTREPS
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by WSTREPS »

have now twice taken time to inform myself about NatureServe and their methods. To sum up my position, it amounts to junk science at it finest.
l will get right to the point. Once again you are 100% correct. Natureserve is used as if it is a legitimate scientific entity. And that is obscene. The only point demonstrated in the rambling attempt at validation is how easily they can cook the books (and do) to make the numbers fit the need. The assemblage of qualifiers that allow for any conclusion to be reached without any genuinely applicable scientific basis. That is the very definition of junk science. No amount of endless blathering (wrongfully-informed) explanations can gloss over the garbage that is Natureserve. I cant believe any intelligent person not possessing a profound bias would even try.

Natureserve is a well funded special interest group and nothing more. To sum it up. Yes. it amounts to junk science at it finest.

Ernie Eison
Jimi
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Jimi »

So Richard - do you get it yet?

Have you yet contributed your life's work to "the permanent record"? It would be a great contribution to both science and management if you could get all your boa, Contia, and other herp observations into a museum collection somewhere. Specifically, in relation to this conversation -

The coordinates, dates, species name and # individuals observed, and observer names, along with any physical evidence such as pickled animals, shed skins, or photographs of animals.

Alternatively you could submit your observations (except the skins or pickles) to ORBIC. But it would be more widely-useful to get the info into a museum. ORBIC - and anyone else - could retrieve the info from a museum whenever they get around to it. Plus, physical material is very important, as you can well appreciate.

cheers
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Richard F. Hoyer »

Jimi,
Our understanding of the Natural Heritage / NatureServe methods and the process used to arrive at ranking results are absolutely identical. In fact, by adding a few more details, you supported and completely confirmed my position that such ranking results are unadulterated junk science at it finest.

So the question becomes, with having the exact same understanding of NH / NS methods, how on earth could two individuals with degrees in wildlife science arrive at completely opposite viewpoints? I suggest the answer must lie in the differences in our understanding of what represents legitimate scientific undertakings.

From my understanding of what constitute science-based undertakings coupled with your detailed description of the methods employed, I am perplexed that anyone would consider such a process as representing a legitimate scientific endeavor. The entire process is rife with the use of perceptions, subjective judgment, and personal opinions. And for that reason, many of the NS ranking results are basically worthless.

The use of such subjective information is total counter to the basic standards for scientific endeavors that requires the use of valid, scientific evidence.
So I have to ask, where is the published scientific evidence that would support most NS ranking results? I have never encountered any published,
scientific evidence that accompanied any N/S state ranking results of species.

This reminds me of a situation that occurred years ago on the national PARC List Serve web site. There was discussion on a particular published paper in which the author’s had used a sophisticated predictive model and came away with a biologically irrational conclusion. Herpetologist Chris K. Dodd then chimed in mentioning, “Garbage in, garbage out.” That is precisely what a large majority of NS ranking results of herps represent – garbage.
The NS ranking of S-3/S-4 for the Rubber Boa in Nevada is a case in point!

A second reason that the Natural Heritage / NatureServe methods do not represent a science-based approach is that of having an agenda and bias. A science-based approach in assessing the status of species would be to objectively examine the numerical abundance of species and identify and review all factors that potentially could either produce positive, negative, or have not affect on populations.

Instead of such an objective approach, the NH / NS method openly seeks to establish the relative degree of ‘rarity’ of species. And they openly seek to identify ‘threats’ rather than also seeking to identify factors that could produce positive impacts on populations.

Third, from what I have been able to glean from accounts on species, no quantitative data accompanies the factors of threats and trends. Stating those factors in broad, general terms has zero scientific value and credibility for three reasons. 1) They lack having any quantitative measure. 2) To a large extent, they represent the assessor’s perceptions and opinions. 3) No valid evidence is cited in support of such stated ‘threats’ and ‘trends’.

Last, you provide a good description of how Element Occurrences (EOs) are used in the NP / NS methodology. Such use of EOs is terribly flawed when used in conjunction with obscure, secretive species, and species whose distribution occurs in remote regions.

I won’t elaborate as it would take take extensive explanations. But equally clear is that nobody in those organizations seems to have done any critical thinking otherwise they should have realized just how flawed is the use of EOs with many species of herps in particular. The Rubber Boa in Nevada is an example of how the use of EOs likely contributed to an erroneous ranking result.

When I examined the NatureServe methods 7 – 8 years ago, I immediately recognized the short comings of the use of EOs. In my exchange of email messages with Eleanor Gaines with that organization in Portland, I explained why the use of EOs was badly flawed for many species of herps and urged she convey my position to her superiors and they phase-out the use of EOs and replace with factors dealing with habitat / habitat association.

Richard F. Hoyer (Corvallis, Oregon)
Jimi
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Jimi »

So the question becomes, with having the exact same understanding of NH / NS methods, how on earth could two individuals with degrees in wildlife science arrive at completely opposite viewpoints? I suggest the answer must lie in the differences in our understanding of what represents legitimate scientific undertakings.
I guess maybe part of it is, I have used it and you have not?

Let me elaborate a bit. When in 2012, I was staring down the job of reviewing and revising the last version of my state's Wildlife Action Plan, I had a choice to make. Would I repeat the methods employed in 2003-4, or would I lead a team to come up something better? I chose the latter option. That begged the question - "how?"

What I wanted to do was run every single species of "jurisdictional wildlife" through some kind of rapid assessment system. My concern was to not maintain and strengthen the current system of haves and have-nots - e.g. birds are well-known and get a whole lot of management effort, whereas snails aren't and don't.

After a whole lot of seeking out and evaluating our options (took about 18 months, no joke) NatureServe's rank calculator was the tool we used. We employed it as systematically as we knew how, using all available occurrence data. The results allowed us to fairly-enough compare the likelihood of eligibility for ESA listing, for about 1000 species. The plan we developed proceeded from that point.
A second reason that the Natural Heritage / NatureServe methods do not represent a science-based approach is that of having an agenda and bias.
I have never said any system is not open to misinterpretation or misapplication. But I will repeat, that it is quite possible to use this methodology and derive results that are good enough to proceed from.

The agenda we had, I have explained above: take "the whole herd", and "cut out" the ones most likely to get into trouble down the trail.
The only bias we had, was against the preexisting order wherein "the rich got richer and the poor stayed poor". Our management responsibility is for the entire set of statutorily-designated wildlife, not just the ones that history has seen fit to deliver to us, well-known.
A science-based approach in assessing the status of species would be to objectively examine the numerical abundance of species and identify and review all factors that potentially could either produce positive, negative, or have not affect on populations.
That would be one approach. It is not the only possible or valid approach. It is also not a very practical approach when you're looking at hundreds or thousands of species.

I have discussed some of the concerns with the utility of abundance estimates. In a nutshell, they aren't worth the effort, for 2 reasons: 1) they require a LOT of effort to get the number, and 2) they leave you with nothing learned in terms of the drivers of the number - positive, negative, or "no effect" as you put it.

You seem to have a problem with EOs. I'm not a fan myself. I have told you there is another option open to anyone using the Rank Calculator - area occupied (basically, range extent). You seem to be open to such an approach, given your staements on number of counties known to harbor this species or that. In the rank calculator, instead of counties one uses small grid cells. It allows a more granular depiction than using "counties" or other such enormous polygons, which necessarily contain many more heterogeneities of land use, land cover, habitat availability, etc.
Third, from what I have been able to glean from accounts on species, no quantitative data accompanies the factors of threats and trends. Stating those factors in broad, general terms has zero scientific value and credibility for three reasons. 1) They lack having any quantitative measure. 2) To a large extent, they represent the assessor’s perceptions and opinions. 3) No valid evidence is cited in support of such stated ‘threats’ and ‘trends’.
The Rank Calculator has an extensive user interface in its "threats" module. If one has quantitative info one can use it. That is rarely the case. Qualitative info is better than no info. No info ("unknown") is an input option, however. You can also enter ranges - narrow or wide, depending on the degree of uncertainty. There is also a place to refer to any "evidence" used in making the assertions or determinations.

Richard, the basic area of disagreement seems to be on the differences between science and management. (Another would be on the various ways to conduct science and to thereby develop valid inferences - I perceive that your views are more narrow.) Stating it briefly, managers need to manage in the face of some serious information deficiencies. Managers do not have the ability to wait until we have perfect information, invariably we have to make a judgement call about when we have "good enough to start with". Putting it another way, management is not solely or strictly a scientific endeavor, there is plenty of subjectivity and judgement required. Good? Bad? Whatever! It's the way it is.

I'll close with a couple of questions:
Have you ever seen this book: https://books.google.com/books/about/Am ... CHQgAACAAJ
Do you recognize the author? Know where he works?
He also wrote this: http://explorer.natureserve.org/servlet ... ina+bottae
Would you dispute any of the major takeaways from that assessment?
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Jimi »

Also, there seems to be some skepticism over the very concept of "threats". Perhaps the skepticism comes from unfamiliarity. Here's an excerpt from page 71 of our Wildlife Action Plan - this is part of the chapter intro. I had about 35 people contribute actual text to this document, but I wrote this page (and had numerous reviewers, over several drafts, critique and mark up the entire document plus all appendices). Perhaps it will lend some useful insight into the concept and its application:
Statewide Threat Assessment
This threat assessment was undertaken strictly from the perspective of wildlife conservation. Some of the identified threats are also necessary and highly valued public services and land uses, for instance, water development, residential development, mining, and agriculture. They provide important values: legitimate, often vital public pursuits, from which all of society benefits. Nonetheless, activities such as removing water for municipal or agricultural uses are indisputably harmful to wildlife and their habitats, which are also legitimate public values and resources; therefore, these actions are still threats from the viewpoint of wildlife conservation. These threats need to be identified in order to determine which are most harmful, and where investments in remedial or preventive actions would be most effective and efficient.

A brief description of the threat-assessment process is provided below. More detail and background on the methods used to identify, measure, and prioritize threats and data gaps can be found in the Threats Methods appendix.
• Every SGCN and key habitat was evaluated, one at a time, for every threat. Species and habitat experts scored all the threats they thought were relevant to each target.
• Scoring consisted of assigning a value for the severity and for the scope of each threat-by-target instance. Using a numerical formula , severity and scope were integrated into a single measure: “threat impact.”
• When all threats to all targets had been evaluated, the data were reviewed to see 1) how many targets are impacted by each threat, and 2) the degree of impact (low, medium, high, very high). See Table T1 for results of this operation. There are 2,145 identified threat-by-target instances.
cheers
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jonathan
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by jonathan »

WSTREPS wrote:
I think there is a genuine need for all animal people to come together and realize that some give and take could go a long way toward making sure the future is bright and that we crank out as many people who want to preserve reptiles and other animals for the future as possible exist.
That's a nice thought but you have to consider where the resistance to that idea is coming from. Certainly not the collector's. The live trade has always been at the forefront when it comes to providing biological data and a willingness to work with everyone.
Actually, no, I would say that the the collector who goes around on field herping forums viciously attacking the character of everyone he personally disagrees with is creating a lot of resistance to the idea of people working together.

You don't post anything about field herping here. Ever. You don't encourage field herpers in any way that I've ever seen. You only come here to attack scientists, conservationists, and people who work with the government, especially if they have ever dared breathe the word "python".

Jimi is telling you, in no uncertain terms, that you are slandering people whom he knows well and who you don't know at all. Why doesn't that lead you to pause for just one second and think that you might be wrong?

I find it easy to believe that you could be wrong, considering that you have previously spent ample energy to viciously slander a project I had participated in despite making it clear that you knew NOTHING about the project in question. You were completely ignorant about the project, filled the thread with lies that were easily disproven, refused to give the slightest evidence to support your lies or even say where they had come from (other than the voices in your own head), and completely ignored both me and the OP when we resoundly corrected your myriad false statements.

Why should we take you seriously on anything else when we know that you lie about the things we have personal awareness of?

I've told you before what you could do to be helpful on this forum. You could post about field herping. It is a field herp forum, after all. You could share some pictures, share some stories, give some insightful examples from your personal experience. In the cases where the science backs up your agenda, you could make well-researched, fact-filled posts that increase everyone else's knowledge of herping.

I would be happy to get on your good side as quickly as you were wiling to stop launching personal attacks on people who you don't even know, and stop negatively characterizing entire groups of people that you really know little about. I would be happy to take advantage of anything and everything you know to increase conservation and correct scientific understanding.

That would be a good example of a commercial collector helping people "come together" and go a long way to making the "future bright" through a "willingness to work with everyone".

But as long as you keep coming onto this Forum solely to launch personal attacks on anyone who fits into one of the categories you hate, you are not helping anyone. You just divide the community further and make this forum a worse place to be.
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by WSTREPS »

Pitfall traps became a big NDOW selling point to justify their shambolic actions. Its very easy to see just how small the pitfall traps are even when compared to the very tiny piece of habitat visible in the picture. 5000 (that's 5 times the high end estimate of traps) provides open coverage of about 1/8 of an acre. This in tens of thousand's of square miles of habitat. Also of note is the traps proximity to one of Nevada's 85000 miles of highway and the towering row of high tension lines running along side it. For a biologist to run around shouting that these traps are somehow imperiling the future of Nevada's native reptiles species, all of which cover vast ranges and display rapid reproduction rates, is nothing short of complete dishonesty. No good biologist could ever make such a claim with any measure of professional integrity. No matter what you might feel about the use of pitfall traps on a personal level. There is no way anyone could possibly make a damming case involving the use of these traps in this instance. By saying the traps are having significant biological impacts that could jeopardize the future of any of the species that might fall into one.

Ernie Eison
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Kelly Mc
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Kelly Mc »

From the moment they fall in to the moment they die. In the bucket or in a 10 gallon tank with some dyed sand and a stand up mini cactus.

Pitfall traps offer nothing good to the world.
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Richard F. Hoyer »

Post 9/30 A
Jimi’s Sept. 26th post contains many interesting issues. I will start my comments with what is mentioned at the end of his post.

I appreciate the candor in your Sept. 26th post but wonder if you realize just how revealing is that information. What you mention confirms all of my prior understandings as to how state wildlife agency’s treat non-game species of wildlife.

As I have mentioned before, what I am going to convey from here on is largely for my benefit. My efforts represent a single person, brain storming exercise. Should anyone else find what I mention as being informative, that would be icing on the cake.

Numerous times I have reviewed NatureServe’s data base information involving western reptiles. I haven’t the foggiest idea of how such ‘canned’, generalized, and imprecise information can be of any value to anyone with respect to the conservation of species, particularly species listed in the state rankings of S-3, S-4, and even S-5.

All of the life history information in such data bases can be found in field guides. And then there is no cited, factual evidence in support of the factors of rarity (abundance), threats, and trends. So such information would be meaningless with respect to the conservation status of any individuals species.

As an example, below I have copied some of the information contained in the data base for the Rubber Boa. There is a complete void of evidence in support of any of what you see below. All such information emanates from personal opinions even if some sort of complex ‘program’ (rank calculator) was involved. “Garbage in, garbage out.” That such information is being presented as if it were science-based is deceitful and dishonest.

Geoffrey Hammerson is the sole, or a contributing author on most of the NatureServe Explorer accounts I have examined. I can give credit that at least those accounts do designate the author and cite references. That seems not to be the case for individuals that produce state ranking results. But completely missing is any specific, science-based evidence in support of the generalized information on abundance, threats, and trends.

Richard F. Hoyer
--------------------------------------------------------------------------------------------------------------------
Number of Occurrences: > 300
Number of Occurrences Comments: This species is represented by many occurrences or subpopulations.
Population Size: 10,000 - 1,000,000 individuals
Population Size Comments: Total adult population size is unknown but surely exceeds 10,000 and probably exceeds 100,000.

Number of Occurrences with Good Viability/Integrity: Many (41-125)

Overall Threat Impact: Medium
Short-term Trend: Relatively Stable (<=10% change)
Long-term Trend: Decline of <30% to relatively stable
Intrinsic Vulnerability: Moderately vulnerable
Richard F. Hoyer
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Richard F. Hoyer »

Post 9/30 B
Quote: “Stating it briefly, managers need to manage in the face of some serious information deficiencies. Managers do not have the ability to wait until we have perfect information, invariably we have to make a judgement call about when we have "good enough to start with". Putting it another way, management is not solely or strictly a scientific endeavor, there is plenty of subjectivity and judgement required. Good? Bad? Whatever! It's the way it is.”

-------------------------------------------------------------------------------------------------------------
First, I would ask why any non-game species would need to be managed when there no valid, science-based information available?

With a total lack of valid evidence that species are of conservation concern, what then occurs is that the listing of species represents a total, non-science approach that only relies on perceptions and personal opinions. So what has taken place has amounted to randomly selecting species then conjure up some imagined conservation concerns. As ample proof is the list of reptiles Nevada has identified as ‘Species of Conservation Priority’. Just read the justifications for listing those species which are all cloaked in generalizations without citing any support from valid evidence.

But by reading between the lines, what you mention is well understood as I can readily place myself in your shoes. Your superiors have assigned you a task and you need to comply. Even if you (and Bryan) might agree with the rational myself (and Ernie E.) have submitted, to become a whistle-blowers of sorts would not be wise from an employment standpoint. To do so would not change anything in the wildlife agency.

So I appreciate your honesty when you mention, “--- there is plenty of subjectivity and judgement required.” That has been one of the major points I have been trying to stress. That is, in listing species of conservation concern, such listings are based mostly if not entirely on subjective information (opinions) yet wildlife agencies state or imply that such listings are science-based.

For the vast majority of listed non-game species I have observed, there is no valid evidence that would indicate they are in need of being managed. Such ‘conservation issues’ are manufactured being the sole product of creative imaginations. I have not attempted to look at Utah’s listed species. But exactly like Calif. and Oregon, the Nevada list of WAP ‘Species of Conservation Priority’ is a classical example of manufactured, fake listing of species being characterized as potentially being at risk and of conservation concern.

With what superiors indicate needs to be accomplished to meet the federal mandate for ‘Species of Greatest Conservation Need’, agency biologists have had to create these imaginary conservation issues by listing gobs of non-games species and making it all look as it such selected species are at risk, potentially at risk, and thus of conservation concern and covering their tracks by indicating that such listings were science-based.

And it comes to mind that perhaps you really believe that identifying and listing such non-game species has conservation value. But from my perspective, unless habitat is also protected, the listing of non-game species has zero conservation value. Thus, all such listings of species in the various categories of conservation concern represents a scam perpetrated against an unsuspecting public!

As I have mentioned, there is no valid reason for managing species not in need of being managed. I again refer back to what I wrote in my initial post in this thread. “Unless there is evidence to the contrary, species exist as self-sustaining populations.” “Self-sustaining populations represent renewable wildlife resources.”

I am open to the prospect I could be wrong in my assessments but I have to be shown, with details, exactly how that might be the case.

Richard F. Hoyer
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Richard F. Hoyer »

Post 9/30 C
As for the issue of ‘threats’, that in itself is a very ‘bad joke’ to say the least. Most, if not all identified threats are in fact, faced by all species across the board, not just the species singled out for review as candidates for some type of listing. To indicate such ‘threats’,as if they only pertain to the ‘chosen’ species proposed for listing, is being disingenuous to put it mildly.

Secondly, by only mentioning threats in broad, non-specific terms, and without quantifying such threats, renders such threat as being worthless.

And last, by not presenting published, supporting evidence, that too makes such ‘threats’ as being meaningless as well.

Richard F. Hoyer
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Richard F. Hoyer »

Post 9/30 D
I have mentioned just how important is leadership. I am fairly certain you (and Bryan?) understand just how bogus is the common wildlife agency policy of placing species in a ‘protected’ status. Such a practice has zero conservation value.

Now there are two possibly explanations that come to mind.
1) The agency leadership believes that placing species in a protected category actually protects species. If that were the case, such individuals in leadership positions are grossly incompetent.

2) The alternative is such leadership knows full well that such a ‘protected’ status does not protect species and thus has no conservation value. If that is the case, then they are being unprofessional, unethical, and dishonest. Both scenarios irritate the devil out of me. For the life of me, I cannot understand what is wrong with being honest.

Your statement about “information deficiencies” is one of the issues I have emphasized. That is, state wildlife agencies have been listing species in various categories of conservation concern without having any valid evidence for supporting such listings. So agencies have deceitfully implied species have been listed using a science-based approach.

Why can’t agencies undertake an honest approach? That would entail, 1) not listing species due to lack of evidence and stating that important fact as being the case. Or 2), if when listing species, inform the public that due to the lack of scientific evidence, species were listed on the basis of the personal opinions of biologists. I dislike the second option as the first option is the only truly professional one.

I do not know what the Utah Wildlife Agency’s guiding principles may be in the management of wildlife. But in Oregon, ODFW states managing species based on “sound-science”. And recently I observed that Nevada states a similar principle of management of wildlife based on science. So explain why wildlife agencies are violating their own stated principles when the manage non-game species of wildlife? Isn’t that being dishonest? My question is really one of being rhetorical as I do not expect for either you or Bryan to answer such a question.

Richard F. Hoyer
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Richard F. Hoyer »

Post 9/30 E
As for my views being narrow, I plead guilty. If that implies I unequivocally disapprove of wildlife agencies violating their own guiding principles of using a science-based approach to managing non-game species, I am guilty. If that implies I consider it to be unprofessional and unethical for wildlife agencies to list species in some category of conservation concern based solely on personal opinions and without any valid evidence, then I am guilty. If it means I condemn wildlife agencies for implying or stating they have listed such species based on science when that is a lie, then I am guilty.

Consider the following: I have now checked twice, once in 1999 and then this past May, with OSU professors in wildlife science and zoology as to what
are the accepted standards of conduct in science and the basis for managing wildlife. I thought perhaps that standards had changes since my undergraduate days and certain personal opinions were now accepted as being scientifically permissible. I learned nothing has changed.

And that is why I posted the abstract by the ASU professor that identifies the scenario of ‘Institutional Corruption’ which fits exactly what has occurred in wildlife agencies. One of the professors from whom I sought input in 1999 was the past Chair of OSU’s Dept. of Fisheries and Wildlife. When I
showed him that ODFW had listed the Sharp-tailed Snake based solely on opinion then falsified information justifying that listing, he said such practices were worse in some federal agencies.

The other professional I contacted at that time was Dr. Stevan Arnold, well recognized herpetologists and then Chair of OSU’s Zoology Dept. He confirmed that the standards had not changed. This May, I contacted the current Chair of OSU’s Dept. of Fisheries and Wildlife, Dr. Selina Heppell. She said I could quote her as follows: “But I can assure you that good science is always at the heart of what we do, and the importance of evidence-based science is heavily emphasized in our coursework.”

If is fact that state wildlife agencies list non-game species based solely on subjective opinions and without any valid evidence, then proclaim or imply to the public that such listings were science-based. So I ask anyone, explain why you believe the above wildlife agency policy is perfectly legitimate.

Richard F. Hoyer
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Richard F. Hoyer »

Post 9/30 F
Quote: “The Rank Calculator has an extensive user interface in its "threats" module. If one has quantitative info one can use it. That is rarely the case. Qualitative info is better than no info. No info ("unknown") is an input option, however. You can also enter ranges - narrow or wide, depending on the degree of uncertainty. There is also a place to refer to any "evidence" used in making the assertions or determinations.”
-------------------------------------------------------------------------------------------------------------------------------

The ‘rank calcular’ represent an overly complex method for churning out ranking results. For a large majority of species, the values use in the rank calculator either have little scientific value such as EOs, or the values that are used only represent subjective opinions. Consequently, the ranking results are basically meaningless at least for species ranked in the S-3, S-4, and S-5 categories. The Nevada example of listing the Rubber Boa as
S-3/S-4 is a clear example. The species has never been the subject of study in Nevada so there is a total void of scientific evidence that would support that NatureServe ranking result.

I can almost hear someone saying, but there are so few E0s (locality records) for the Rubber Boa in Nevada. And that is correct. So anyone explain why such a lack of locality data represents valid scientific evidence. I already gave the example of the Common Sharp-tailed Snake in Oregon as to why EOs, or any form of locality sighting information that has not truly been updated by research or extensive surveys for species, cannot be used as if such information was meaningful in assessing either a species’ true distribution or abundance. Our knowledge of the distribution of species, particularly here in the west, is always well less than 100%. That is particularly true for the more obscure species, and species whose distribution occurs in very remote regions of the western U.S.

So Jimi, here is an area in which I completely disagree with your position. You mention that when there is no science based evidence (quantitative information) which is almost always case with assessing the categories of ‘rarity’, ‘threats’, and ‘trends’, then qualitative information (subjective opinions) is better than no information. Explain to me how anyone could consider doing so represents a science-based approach.

Using qualitative formation in the rank calculator that basically amounts to guessing, that in turn leads to manufacturing fake conservation issues where none really exist. Again, the NatureServe ranking results of the Rubber Boa and the NDOW designating the boa as a ‘Species of Conservation Priority’ are examples of a fake, manufactured conservation issue.

As mentioned, the species has never been the subject of research in Nevada so there is zero science-based in formation on the species. That means all of the input that was used to designated the species as S-3/S-4, and then identified the boas as a ‘Species of Conservation Priority’, had to be based solely on opinions. That means there was a total void of any legitimate science involved.

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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Richard F. Hoyer »

Post 9/30 G
If I could wave a magic wand to effect changes in wildlife agencies, I would transfer all biologists in the Wildlife Diversity (non-game) Divisions into the Game Divisions and replace them with the biologists in the Game Divisions. In that manner, the former biologists could gain an understanding that all wildlife represent renewable resources. They likely would also learn that with very uncommon if not rare exceptions, wildlife resources occur as sustainable populations. And then as true public servants should be, they might begin to work on the behalf of the public and not against the public.

The evidence of the latter is glaringly apparent. Removing species from public access by placing species in a hands-off protected status is one example when in fact, the listing of such species was accomplish by unprofessional, unethical and dishonest methods. Such actions by wildlife agencies represent a mean spirited, reactionary approach as such a policy has zero conservation value.

Secondly, I have seen a fair number of individuals on this forum profess their support for wildlife agencies having bag and possession limits. So to those individuals I ask, do you have any understanding as to why game species have bag and possession limits? And if you do, explain why non-game species also need bag and possession limit.

Of course, for game species that have considerable demand, bag and possession limits were place into effect to prevent such game species from being over harvested. So then from a rational, biological point of view, explain the value of having bag and possession limits for non-game species that number in the millions and for which demand is infinitesimal to non-existent.

Let me point out another fact of life that pertains to non-game species and the factor of demand . The recreational collecting of herps for personal use is a self regulating enterprise. It doesn’t take long for most, if not all individuals to come to the realization that maintaining a large contingent of one, or many species takes a great deal of time and in some cases, much expense. Sooner or later, individuals stop collecting and more often than not, pare down the number of specimens they maintain.

Wildlife agencies imposing bag and possession limit on non-game species is biologically irrational and indefensible. It can only represent another mean spirited posture against the public.

Richard F. Hoyer
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by jonathan »

Richard F. Hoyer wrote:First, I would ask why any non-game species would need to be managed when there no valid, science-based information available?

With a total lack of valid evidence that species are of conservation concern, what then occurs is that the listing of species represents a total, non-science approach that only relies on perceptions and personal opinions....

I am open to the prospect I could be wrong in my assessments but I have to be shown, with details, exactly how that might be the case.

Richard F. Hoyer

Richard, we've discussed this issue before and it doesn't seem to have changed your tact at all. So I'm going to try a different approach.


#1: Approximately how many non-game species exist in Colorado?

#2: How much money do you believe it would cost to launch a completely scientific inquiry into just one of those species that conclusively determined abundance, trends, and threats to your satisfaction? How many years and how many people do you think it would take?

#3: What is the approximate total budget for such endeavors in Colorado?

#4: At what point did such scientific data conclusively showing abundance levels and trends first become available for the Blackfin Cisco, Eskimo Curlew, Tacoma Pocket Gopher, Wyoming Toad, Dusky Seaside Sparrow, etc.? Should conservation decisions on those species have waited until such data was available?



Can you answer those four specific questions?
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Jimi »

Richard, you're an interesting guy to talk with. We agree on a fair amount. We definitely disagree on some things. But some things you don't understand, and you think we disagree about them. If you knew more, perhaps you'd change your mind.
And it comes to mind that perhaps you really believe that identifying and listing such non-game species has conservation value. But from my perspective, unless habitat is also protected, the listing of non-game species has zero conservation value. Thus, all such listings of species in the various categories of conservation concern represents a scam perpetrated against an unsuspecting public!
That's a pretty jaundiced perspective with a pretty insulting conclusion. Are you hearing me?

I told you, we looked at all species - the few that are well-known, and the many that are poorly known. The only purpose of the assessment & ranking exercise is to "flag" species for further examination - which could range from scouring museums, HerpMapper, iNaturalist, HERP etc. for recently-added records, all the way to formal, designed multi-state surveys to generate new information.

I don't know how it works in states other than the ones I have worked in, but where i have worked THERE IS NO AUTOMATIC REGULATORY IMPLICATION OR RESULT of these assessments & rankings. If you think so you are deluded, and you need to rethink your assumptions. If further examination suggests some kind of regulatory designation is required, then that route may be followed. I've never worked any place where there isn't a rule-making, public process that's part of a regulatory designation. Public processes run a wide spectrum in quality, degree and kind of participation offered and allowed, etc. - I make no excuses for the bad ones. But there are some good ones, and there's a way to make the bad ones better. I have written on this topic here for a long time. I don't need to go into that again right now.

As for habitat being "protected", that is one common result of state regulatory designation - probably the most common one, actually. Protection comes in many flavors however - not just acquisition, and often doesn't extend to private lands. If it does, usually it's via some financial nexus like Farm Bill funds. Some state land & regulatory agencies are affected, and oftentimes federal agencies (land management, & others like DOT & DOD) are helpful or just sucked on to some extent. It all depends on relevant statutes, rules, policies and guidelines - almost always the state wildlife agency has no control here.

Most commonly a state regulatory designation results in some sort of avoidance or minimization of impacts to habitats, less commonly in some sort of compensatory mitigation for lost habitat values. "Impact assessment" is the generic name of such programs within wildlife agencies. As for "hands-off" designation for personal use of or access to a species, that is rarely an outcome of a Heritage assessment. Sadly, there is not always wonderful coordination and collaboration between Heritage programs and the folks who make the user-access designations.
As I have mentioned, there is no valid reason for managing species not in need of being managed. I again refer back to what I wrote in my initial post in this thread. “Unless there is evidence to the contrary, species exist as self-sustaining populations.”
The circularity of this logic is impressive. How would someone know a species was in need of management, if they didn't take a look around periodically? THIS IS EXACTLY WHY THESE ASSESSMENTS ARE DONE. Seriously, where's the evidence supposed to come from? The evidence fairy? We need a way to periodically look at all species quickly and cheaply, and get a decent idea about which ones we need to look at more closely & carefully and see what - or if - we might do about them. That's all these periodic assessments are about. Most of the time the species we think maybe there's an issue, it turns out with a little bit of looking "nope, no issue". It's an iterative process - literally, a rotation through the whole list - where we winnow down to what really needs attention, and never take our eyes off anything for too-too long. Surely you can see some logic and value in that. There is no evidence fairy, and there's no sugar daddy either.
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by WSTREPS »

The evidence of the latter is glaringly apparent. Removing species from public access by placing species in a hands-off protected status is one example when in fact, the listing of such species was accomplish by unprofessional, unethical and dishonest methods. Such actions by wildlife agencies represent a mean spirited, reactionary approach as such a policy has zero conservation value.
It certainly benefits the careers of those who push for this type of thing. That's what it comes down to. About having bag and possession limits. There are no reliable ways to measure the population size of reptile species in almost all circumstances. What is most agreed on is that you can only count a fraction of the number actually present. Only when populations of reptiles become biologically abundant is it possible to find any reptiles. So while you can not determine the species total populous with any accuracy.You can understand that when a small species is wide spread and is easily found in abundance, its numbers are in the hundreds of thousands and probably millions. You can also take this count involving a fraction of the number actually present and create artificial rarity.

In Nevada you can kill a variety of native mammals in unlimited numbers but they should have bag limits or now a full ban on shovel nosed snakes and fence lizards?

Nevada has no bag or possession limits for the take of a variety of native mammals. NDOW biologist Jason Jones never said one peep about that. Jones only mammal talk was about finding mammal's in pitfall traps but he never would say what they were. He didn't want to lose the shock value. Had he said that these mammals were mostly invasive rat species and other pest , that certainly wouldn't have helped his deceitful narrative.
So then from a rational, biological point of view, explain the value of having bag and possession limits for non-game species that number in the millions and for which demand is infinitesimal to non-existent.
There isn't a value of any kind. That is exactly why NDOW mouth piece Jason Jones did not approach this from a rational, biological point of view. Instead he did everything possible to mislead and manipulate, he was as deceitful as he could be. The same can be said for his supporters who bend and twist looking for any explanation they can without ever addressing the obvious. Ignoring the fact that Jason Jones presentation was fraught with discrepancies, inaccuracies, duplications and unreliability. The excuse makers turn to talk about birds and gophers , personal attack, whatever they can. But nothing about the actual facts involved, the reptiles or the unprofessional and unscientific approach used by NDOW biologist Jason Jones.

Ernie Eison

NDOW Jason Jones activist not scientist presentation was filled with lies and deceit taken straight from the internet. NDOW biologist spent more time talking about off topic and off color things he took off the web bashing the live trade, then he did about the biological aspects and proper managing of Nevada's reptile populations. Here are a few examples taken from NDOW biologist Jason Jones ridiculous presentation.
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Richard F. Hoyer »

Jonathan,
At the end, you ask, “Can you answer those four specific questions?” No problem.

Question #1) The answer would vary depending on whether or not you include invertebrates as representing non-game species. But if you are interested in knowing the number of non-game vertebrate species, go to the following web site and you can count them for yourself.
PDF]Chapter 10 - Nongame Wildlife - Colorado Parks and Wildlife

Questions #2) My estimate indicates it would take about $ 0.52 to launch a scientific inquiry on any one species. That is based on a salary of $125,000 for the head of the Colorado Wildlife Agency taking a half a minute to make the decision and proclaim that the state is to launch such a study.

As for the second part of your #2, my detailed estimate indicates it would take about 124.7393 years +/- 1.254 yrs., with a confidence level of 0.0017482 given that an average of 32.275 persons were assigned full time employment toward that project over that period of time.

Question #3) I estimate it would take 1.984 billion dollars but that does not include any yearly increase in cost of living allowance and other such factors. So consider that as just a starting bare-bones estimate. So I am curious as to what estimates did you arrive at for those three questions?

All joking aside, it seems to me you posed your questions in anger, frustration, or both. And that may be due to the fact I have not communicated well enough to get across my positions. Or, there is the possibility you have overlooked or misunderstood what I have written. A clue to both of those possibilities is your question #4

Along the way, I have mentioned, but may not have emphasized, that wildlife agencies were listing species in some category of conservation concern WITHOUT any valid evidence whatsoever. As an example, I pointed out that Nevada listed the Rubber Boa as a ‘Species of Conservation Priority’ when there was zero evidence for such a listing. And I mentioned that was case with the Sharp-tailed Snake here in Oregon.

The point being, the professional and ethical approach would be to have some valid evidence before a species is considered or proposed for listing let alone having a species listed without any valid evidence whatsoever. So the question then becomes what constitutes ‘valid evidence’? And that can vary between individuals even in the academic / scientific community.

As mentioned, I contend that perceptions, personal opinions, and similar unsupported and totally subjective information are not acceptable as being valid evidence. And to see if my understanding was proper, I conferred with academic professionals that confirmed the position I have taken. And I also cited that wildlife agency guiding principles indicating they are to manage by science-based processes.

So in reference to the implications in the two question in #4, a comprehensive study of any species is not needed to consider a species as a candidate for review. What is needed is some valid evidence.

Richard F. Hoyer
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Bryan Hamilton »

Ernie,

It must be tough to lose so hard, so often. In spite of your lies, bile, and slanderous attacks. {someone has read and taken to heart "Rules for Radicals". Or was it "The Prince"?} I hope they are paying you well for your effort and not for your results. This ugliness never gets results, even if the cause is just. Which in your case, it ain't.

You know the post on amphibian disease right below this is the next battle. Disease is the new habitat loss and its going to hit you and your boys real hard.
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Richard F. Hoyer »

Jimi,
As for what you mention about ‘some things I don’t understand’, I am well aware that by just looking from the outside in, I could very well have a somewhat different view than if it was the other way around. That is why I sometimes mentioned the ‘disclaimer’ that I could be in error.

Late last night for the first time, I took a peek at the Utah Wildlife Action Plan. Had I continued to examine that document, I never would have gotten to bed. I glanced at the information in the tables on ‘threats’ but could not find (possibly over looked), just how such threats were determined and scored. I believe someone would need to take me in hand and try to explain just how how that process was used and what it means. Just at a glance, it seemed as if a great deal of opinion must have been involved.

I noted the Sonoran Mt. Kingsnake and Milksnake were listed. So here are some questions to consider.

With respect to the issue of ‘threats’, can you tell me what threats those two species face that are different from the threats faced in Utah by the Rubber Boa, Common Kingsnake, Gopher Snake ,Racer, Night Snake, etc.? Do those two species really have threats that are not the same for all or most species of snakes in Utah?

And for the threats that are the same as for most other snakes in Utah, is there any difference in the magnitude of those threats for the two tricolored snakes that are different from the other species?

From my long distance soap box, I cannot think of any meaningful threats for those two snakes that would different from the other non-listed species. And I can’t imagine that any such threats that all snakes face in Utah there would be of a significant difference in magnitude for those two species.

So if there are no threats that are different, and the magnitude of common threats are about the same as some or all non-listed species of snakes, then what factors (evidence) singled out those two species as to have them warranted for listing? For the sake of not looking incompetent, I hope that the issue of collecting is not mentioned as being a factor.

I may comment later on some other aspects you cover.

Richard F. Hoyer
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Kelly Mc »

Instead Mr Hoyer, why dont you pour yourself a nice brandy, put your feet up and let yourself meander in Chapter 1 The Serpent's World, just for the positive old joy of it.

I really think you should, Sir.
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Kelly Mc »

I do wonder what those who inspired us, would think of reptiles stuffed in a soda bottles for some dirty money.

And using "not enough data" as an excuse.
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Kelly Mc »

Before you open your mouth about poaching versus legal Ernie, the Legal trade is just as bad.


Only at the Wholesalers they are in containers piled together. The dead ones sorted out, sometimes, but that "depends".

How do I know? Because Ive seen it. Thats how I know.
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by WSTREPS »

Your statement about “information deficiencies” is one of the issues I have emphasized. That is, state wildlife agencies have been listing species in various categories of conservation concern without having any valid evidence for supporting such listings. So agencies have deceitfully implied species have been listed using a science-based approach.


Absolutely. Staying topical. In this case the state wildlife agency didn't need any valid evidence. It was within their rights to enact any protocol they saw fit.

"The court should give great weight to an agency's interpretation of its own regulations."

Read that quote. Rule number 1. DON'T LET THE FOX GUARD THE HENHOUSE - Don't assign a job to someone who will then be in a position to exploit it for his own ends.

It was a perfect situation for NDOW biologist Jason Jones to pop in and make a little name for himself to help boost his career. The burden of proof falls on the collectors to demonstrate that no biological harm is occurring. Its a classic kangaroo court. Jones runs to the commission and makes accusations that he can not factually back up. Then Jones is given free reign to speak at length. Present a lengthy mostly off topic slide presentation filled with misnomer and custom designed press fodder, has personal meetings with the board chairmen, gets his gal-pal from the Nevada division of Bio diversity to do the same.....and they are not required to prove anything. The collector's (7 total 6 only do it part time) were not notified of the first meeting and are given a few minutes each to make their case. And are forced to prove.

Add to that Jason Jones made irresponsible comments to the press who loved the grossly misleading photos and photo shopped captions (see press fodder), and then blend in the legal overtures from the Center for Biodiversity. The fix was in from the start. With the threat of bad press , law suits and having to go against the wishes of the states anointed scientific authorities. The board took the safe way out and put little feather in their own caps. It was shameful but expected. It is as dishonest a situation in government as you will ever see.


NDOW biologist slide presentation to the board was over half comprised of irrelevant activist material taken from the web. Out of the 50 + slides not counting duplicates Jones presentation included only 3 that vaguely referenced the natural biology's of the actual animals in question. Below NDOW Biologist Jason Jones first slide in his off topic and misleading press fodder driven "scientific" board presentation. This How NDOW Biologist Jason Jones started his "scientific" presentation to the board. The photo shopped caption caption in bold red letters.
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Bryan Hamilton
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Bryan Hamilton »

I used to collect baseball cards and stamps. That was more fun than this thread.
Jimi
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Jimi »

I used to collect baseball cards and stamps. That was more fun than this thread.
Quite. Jeez.

Richard, how about starting another thread? We've hijacked this one enough. I'll start you off with something you asked:
then what factors (evidence) singled out those two species as to have them warranted for listing?
1) Look at how the SGCNs were identified - how we pulled about 140 species of mollusks, crustaceans, herps, etc out of the thousand or so we looked at. There's a chapter, and an appendix discussing methods.

2) Don't use the language "warranted for listing" with this process or product. That term is specific to something else entirely and bears zero relation to what we have been discussing.
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Kelly Mc
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Kelly Mc »

Skeleton keys and old lock keys. I have them hanging on a cedar board. And all the forceps I ever worked with. I want the one from my last to be buried with me stuck in my back pocket.
Richard F. Hoyer
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Richard F. Hoyer »

On Oct. 1st., I took a peek at the Utah Wildlife Action Plan. Since then as time has allowed, I have been scanning some of the information in that plan. It constitutes an extremely comprehensive and complex undertaking that must be applauded in its scope and details.

The document has 374 pages and yesterday, I stopped at page 200. I will scan the rest of it sooner or later. Although I did not read all 200 pages nor have I completed my review, I still have the impression that this document is the best I have observed thus far in which a state wildlife agency has listed non-game species in some category of conservation concern.

One major flaw is that the Utah Wildlife Action Plan placed trust in NatureServe’s methods and in their ranking results for individual species.** And NatureServe’s method and their ranking results are typical of “Garbage in, garbage out.” So some of the listed “Species of Greatest Conservation Need’ (SGCN) are questionable. The two glaring examples I alluded to in my prior post are the Milksnake and Sonoran Mt. Kingsnake.

And then if I have correctly interpreted what I read, another weakness is that Utah followed NatureServe’s methods of assessing the categories of ‘rarity’ ‘threats’, and ‘trends’ on the basis of opinions. So their result are not representative of sound-science but to their credit, they do not claim that to be the case.

I believe Jimi mentioned they needed a quick and inexpensive means for assessing species so in that light, I can understand the basis for relying on NatureServe. On the other hand, I continue to be baffled as to why wildlife agencies, and even some individuals in the academic community, do not realize that NatureServe’s methods are not scientific and that all of their ranking results are the produce of subjective judgment (opinion). And as mentioned previously, the use of opinions as if such were factual is unacceptable in scientific endeavors.

Richard F. Hoyer

** (From Page 200) “Methods” (The following is referring to the three categories of Rarity, Threats and Trends)
“Scores for these three factor categories are integrated using the NatureServe Rank Calculator to derive each SGCN's S-ranks and N-ranks. Those ranks were a core component of the process for selecting SGCNs from the entire list of jurisdictional wildlife (see the SGCNs Methods appendix for more details).”
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WSTREPS
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by WSTREPS »

On the other hand, I continue to be baffled as to why wildlife agencies, and even some individuals in the academic community, do not realize that NatureServe’s methods are not scientific and that all of their ranking results are the produce of subjective judgment (opinion). And as mentioned previously, the use of opinions as if such were factual is unacceptable in scientific endeavors.
How can you be baffled? Its compiled by "scientist" so it is "science". That is all these wildlife agencie people understand. In addition why would they ever question something that can create instant scientific credibility where there is none when and where they need it. Junk science is the bedrock foundation of what is called environmental conservation and wildlife protection in 2017.

Naturally members of the academic community support this crap. They invented the scheme and use it to their advantage. Even if some don't truthfully buy into it. As has been amply demonstrated people in the academic community are reluctant (afraid) to call out one of their own and rock the boat.

The next question is what did NatureServe’s methods have to do with the travesty involving the NDOW and their mouth piece biologist Jason Jones?

Ernie Eison

NatureServe’s method and their ranking results are typical of “Garbage in, garbage out.” Correct. Then its garbage back in and the next round of bogus wildlife legislation and pork barrel spending out.
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Kelly Mc
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Kelly Mc »

There are many sciences. If a person is smart, fortunate enough and focused enough to attend university and get a degree but chooses to work in wildlife there is something at its core and for alot of people it is probably the Wildlife itself.

I think it would be fair to say that to be enamored with living things, in a deep regard would be present in even the most stoic of personalities for a person to choose to be a biologist in the wildlife field.

So where there is bias involved it must come from this. And a knowledge of human nature and its unsurpassed opportunism.

Richard Hoyer speaks of science in religious tones. He expects an impeccability of data where in some cases it is currently impossible to garner. Other disparities are more obvious, he has cited.

But it is all dissected and wrung out to justify commercial collection. Of all things.

Richard Hoyer has written more disproportionately and spent more time posting to - underneath it all - justify commercial collecting than any thing he has written on FHF about Sharp Tailed Snakes and Rubber Boas, of which he is an expert of highest standing. He has the same kind of issues with wildlife agencies about them, but its commercial collecting he is desperate to defend - in the name of perfect science.

If some bias is involved in the wildlife listings it is not that complicated to see why. Perhaps it is biased. Perhaps there is a hint of 'by any means' at play.

There are greater wrongs.
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Jimi »

Hi Richard, thanks for bearing with me here. I think this is an important conversation, I appreciate the time you're putting into it. Let me offer an example to answer some questions & statements you posed. First your material:
One major flaw is that the Utah Wildlife Action Plan placed trust in NatureServe’s methods and in their ranking results for individual species...

And then if I have correctly interpreted what I read, another weakness is that Utah followed NatureServe’s methods of assessing the categories of ‘rarity’ ‘threats’, and ‘trends’ on the basis of opinions. So their result are not representative of sound-science but to their credit, they do not claim that to be the case.

I believe Jimi mentioned they needed a quick and inexpensive means for assessing species so in that light, I can understand the basis for relying on NatureServe. On the other hand, I continue to be baffled as to why wildlife agencies, and even some individuals in the academic community, do not realize that NatureServe’s methods are not scientific and that all of their ranking results are the produce of subjective judgment (opinion). And as mentioned previously, the use of opinions as if such were factual is unacceptable in scientific endeavors.
OK, understand we don't just "trust", it's much more of a "give some initial credence, then verify".

I could go into detail about how there's a big difference between a huge, broad, but pretty shallow planning effort, and the fine-detail work of individual species assessments. The "verification" part of what I said above. I could also go into detail about the difference between planning and implementation, and the necessary but insufficient role of planning in conservation. I'm gonna skip all that, and just give an example of some results. Below is something that came out just a couple of hours ago. To me, it totally validates the effort I put into my job, and the approach I take to steering all that effort. It's a lot of effort, so the steering matters a whole lot. Please read this press release closely, and give it some thought. Oh yeah, all those snails that occur in my state were "listed" (I would rather say "rated" or something, the "L-word" is just too freighted) as SGCNs in our state Wildlife Action Plan. And please remember, the very purpose - explicitly stated, right up front - of that plan is to prevent species from getting listed as Endangered or Threatened species under the US ESA.

All those snails are NatureServe-methods-ranked as G1, N1, S1. Those rankings are correct - these are animals with global populations existing in just one, two, or up to about 6 localities. These localities are just little springs out in the desert - tiny tiny wet spots in a giant sea of dry rock and dirt. But we think for now we've got the threats and potential threats to their existence well-enough in hand, to keep their management where it is now, as it is now - no need for anyone else to step in and assume a lead role, and dictate major changes in management activities. "We've got it, we're good" is what I'm saying. Now, if things change - say, if Las Vegas comes and sticks a big straw into the aquifers that discharge into the springs - "Not Warranted" could totally flip to warranted and an ESA listing. So a lot of what the state wildlife agencies and their chain of command up to the governors do, working with counties and legislatures too, is to work with user groups like SNWA to ensure there's nothing done to invite a listing.

As I keep saying - it's easy to be a harsh critic on the internet. It's not so easy to be an effective conservationist. And it's no fun to be a target of the peanut gallery.
FOR IMMEDIATE RELEASE

October 4, 2017
Contact: Dan Balduini (702) 515-5480, [email protected]

Fourteen species of springsnails in Nevada and Utah found to be stable, don’t require Endangered Species Act protection

LAS VEGAS — Following a thorough review of the best available science, the U.S. Fish and Wildlife Service has determined that 14 species of springsnails in Nevada and Utah, all have stable populations and distributions, and do not require protection under the Endangered Species Act.

Springsnails are small aquatic mollusks found in fresh or brackish water, and in moist soil near springs. Most are no larger than a BB pellet. The 14 species reviewed by the Service are unique to freshwater springs in the Great Basin and Mojave Desert.

In conducting this review, the Service solicited information from state and federal agencies, Native American tribes and the scientific community. The Service’s review indicated the current numbers and distribution of the 14 species are similar to their historical levels and that current and future stressors do not pose significant threats to their survival. The review also looked at the springsnails’ habitat, potential overutilization, disease and predation, adequacy of existing protections, and other natural or man-made factors.

The species covered in the not-warranted determination (known as a 12-month finding) were included in a petition from the Center for Biological Diversity, the Freshwater Mollusk Conservation Society and several individuals.

This finding and supporting documents are available online at http://www.regulations.gov (Docket Number FWS-R8-ES-2011-0001), or at http://www.fws.gov/nevada /. Supporting documents used in preparing this finding are also available for inspection by appointment, during normal business hours at the Southern Nevada Fish and Wildlife Office in Las Vegas at 4701 North Torrey Pines Drive, telephone 702/515-5230, facsimile 702/515-5231.

The U.S. Fish and Wildlife Service works with others to conserve, protect, and enhance fish, wildlife, plants, and their habitats for the continuing benefit of the American people. For more information about our work and the people who make it happen, visit http://www.fws.gov/cno/ or connect with us via Facebook, Twitter, YouTube, and Flickr.

-FWS-
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Kelly Mc
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Kelly Mc »

There are basal narratives that subtext adamant threads.
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WSTREPS
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by WSTREPS »

So the focus of the thread isn't lost The question is what did NatureServe’s methods or snails or Utah have to do with the travesty involving the NDOW and their mouth piece biologist Jason Jones or his tabloid style science ?

In the days prior to the final ruling NDOW biologist Jason Jones submitted a proposal to the commission board. This proposal strongly pushed for a full ban on commercial collection. Included in this proposal was a red herring so to speak. In the second section there was a list of proposed quotas compiled by Jones.The list was comprised of the 23 species Jones deemed commercially viable. This included 9 lizard species and 14 snake species. Jones gave a zero quota to the top 4 most commercially viable species. Others shovel nosed snakes for example he gave an annual take of 10 a yr per collector. The highest was fence lizards with an annual take of 50. It certainly begs the question how did the pragmatic (sarcasm ) Jones devise such a list in a matter of days. How could he have determined that 4 species that have been collected without limits for half a century without showing any demonstrably negative population effects. Suddenly could not withstand the loss of even a single individual. This an especially mystical feat considering that by his own admittance. Jones doesn't know much about the natural ecology's of most if not all the species listed.

Its not the money in the illegal pet trade that's bigger then heroin, that's a total lie told by the Jason Jones of the world. Its the phony conservation business along with its henchmen junk science accomplices that is bigger then drugs.

Ernie Eison
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Bryan Hamilton
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Bryan Hamilton »

The real travesty is that you are still allowed on this forum. I guess its better to give you an outlet than bottle all this up.
Richard F. Hoyer
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Richard F. Hoyer »

Ernie,
How on earth did you come across the proposal you say was submitted by Jason Jones to the Nevada Wildlife commission? Are you certain of your information? What you mention is so bizarre, I if find it hard to believe! If the Rubber Boa was on the Jones proposal, what limits did he indicate for the species?

If this Jones is the same individual that sometimes posted on the Kingsnake forum, or PARC, or even perhaps in the earlier days on this web site, and if my recollection is correct, at that time he was anti-collecting indicating incidental collecting could harm species. Below is part of the Nevada WAP ‘Species of Conservation Priority’ account of the Rubber Boa. What is mentioned about the boa seems to ring a bell as in his posts, the Jason Jones mentioned something similar. But then again, I could be all wet.
-------------------------------------------------------------------------------------
“CONSERVATION CHALLENGES:”
“Possibly vulnerable to excessive collection due to its market desirability and relatively high wholesale prices per specimen.”
-------------------------------------------------------------------------------------
It is astounding that anyone could believe excessive collecting could leave the Rubber Boa population in a vulnerable position.

Richard F. Hoyer
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Richard F. Hoyer »

Jimi,
The Utah WAP is an imperfect document as I believe you have mentioned or inferred. Below are what may be some of those ‘imperfections’.

The issue of both tri-colored kingsnakes comes to mind. Of course, I suspect it is unlikely there exist any published scientific research that relates to rarity, threats and trends for those species. So is it possible you could find out on what basis those species were ranked S -3? (Few ‘EOs’?)

I noted that for the Midget Faded Rattlesnake, roads and railroads are indicated as being a ‘threats’. Without speaking to the person or persons that consider roads and railroads as threats, I do not know their rational. Do you have any idea why roads and railroad would pose a threat to the Midge Faded Rattlesnake (or any other snake for that matter)?

I see fire and droughts mentioned as being ‘threats’. Both are natural occurrences that have existed for millions of years. And all existing species in Utah have encountered multiple episodes of both fire and droughts for eons and long before any humans set foot in North America. And yet they have remained as self-sustaining populations. So I find it odd that those two factors being considered as threats for terrestrial species.

For my own ‘brain storming’ satisfaction, I may later elaborate on the use of ‘EOs’ that NatureServe uses for assessing the category of ‘rarity’.

Richard F. Hoyer
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Kelly Mc
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Kelly Mc »

While doing a light peruse I came across a dealer in the commercial reptile trade and its the same Ryan that refers to you as his father in a rubber boa care info site.

You have a close relative in the commercial reptile industry but have not mentioned it throughout copious text with numerous use of the word bias.
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WSTREPS
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by WSTREPS »

Ernie,
How on earth did you come across the proposal you say was submitted by Jason Jones to the Nevada Wildlife commission? Are you certain of your information? What you mention is so bizarre, I if find it hard to believe! If the Rubber Boa was on the Jones proposal, what limits did he indicate for the species?
I searched online its pubic record and YES 100% certain. At the Aug meeting the board instructed the NDOW to draft and submit 2 regulation proposals. The memorandum with the 2 regulation proposals one an all out ban the other as good as an all out ban was submitted by Jennifer Newmark, Administrator, Wildlife Diversity Division on Sept. 1 2017 following protocol and not officially Jones. But Jones certainly compiled the list and accompanying strangulating stipulation's and recommendations as these stipulation's and recommendations were essentially direct quotes from his board presentation. Jennifer Newmark represents nothing more then a glorified secretary.

Its meaningless now but....................

I posted the entire list along with the attached special conditions previously in this thread. I did it that way instead of posting a link so that it would be right there in front of anyone reading this thread to see. People will argue endlessly but wont take the time to clink on a link and read a page so that they know what they are arguing about. I would like to make two corrections it was 17 snake species not 14 as previously stated and the top 5 not 4 commercially viable lizards listed with a zero quota.

The species and yearly quota as follows,

California kingsnake (Lampropeltis californiae [getula]) 10
Desert nightsnake (Hypsiglena chlorophaea) 10
Glossy snake (Arizona elegans) 10
Gophersnake (Pituophis catenifer) 10
Long-nosed snake (Rhinocheilus lecontei) 10
Mojave patch-nosed snake (Salvadora hexalepis) 10
Red racer (Coluber flagellum) 10
Striped whipsnake (Coluber taeniatus) 10
Terrestrial gartersnake (Thamnophis elegans) 10
Western black-headed snake (Tantilla planiceps) 10
Western groundsnake (Sonora semiannulata) 10
Western yellow-bellied racer (Coluber constrictor) 10

Venomous Snakes
Western lyre snake (Trimorphodon biscutatus) 5
Great Basin rattlesnake (Crotalus oreganus) 5
Mojave rattlesnake (Crotalus scutulatus) 5
Panamint rattlesnake (Crotalus stephensi) 5
Speckled rattlesnake (Crotalus mitchellii) 5

Eastern fence lizard (Sceloporus undulatus) 50
Great Basin skink (Plestiodon skiltonianus) 30
Great Basin whiptail (Aspidoscelis tigris) 50
Northern sagebrush lizard (Sceloporus graciosus) 50
Ornate tree lizard (Urosaurus ornatus) 50
Western fence lizard (Sceloporus occidentalis) 50
Yellow-backed spiny lizard (Sceloporus uniformis [magister]) 30
Zebra-tailed lizard (Callisaurus draconoides)
30 Side-blotched Lizard (Uta stansburiana) 50

ZERO QUOTA

desert iguana
western chuckwalla
long-nosed leopard lizard
Great Basin collared lizard
desert horned lizard.

Unlimited Quota

Bullfrog (Rana catesbeiana)
Spiny softshell turtle (Apalone spinifera)
Mediterranean house gecko (Hemidactylus turcicus)
Bow-footed gecko (Cyrtopodion scabrum) unlimited
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Kelly Mc
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Kelly Mc »

Huh. Good numbers on the snakes for CB breeding programs, and for many people enough left over to gift or sell to friends or selected clientele - it was stated more than once by the pro collect posters how tiny and insignificant the market is, remember?

Astute number of lizards, imo, if the common are used as feeders for a lizard specialist, throughout a year; especially if the snakes put to a conventional brum period. No real market for the common guys - except that, unless of course they are sold in lots to the stores - "What's your cheapest lizard?" [Quote X 1000, ask anybody in the business]

If the lackadaisical and ethically vacuous didnt blow it per the pit fall traps, no ban would have probably happened..



For every action there is an equal and opposite reaction.

- 'Good' Science
Richard F. Hoyer
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Richard F. Hoyer »

Thank EE for the information.

As I mentioned somewhere along the line, how important is leadership. It seem clear that neither the head of the NDOW Wildlife Diversity Division nor Jason Jones have any real understanding of the basics that involve wildlife populations.

And I thought they were so concerned about over-collecting of the Rubber Boa, it would be on their list -- which it wasn’t. As nutty are those two individuals in dealing with non-game species of reptiles in Nevada, they have yet to exceed the lack of competency shown by some individuals in the CDFW that are in charge of ‘managing’ the species in herps in that state. Long story.

But a much different story emerged 2 years ago when I contacted two biologists in the CDFW Game Division. Top professionals!!

Richard F. Hoyer
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Bryan Hamilton
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Bryan Hamilton »

You guys, stop it! Really start a new thread.

edited to remove snarky comments. Just start a new thread already.
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by chris_mcmartin »

Kelly Mc wrote:Huh. Good numbers on the snakes for CB breeding programs, and for many people enough left over to gift or sell to friends or selected clientele - it was stated more than once by the pro collect posters how tiny and insignificant the market is, remember?
If I'm following the news correctly, the proposed limits, which seem fairly reasonable as you state, were dismissed in favor of an all-out BAN on commercial collecting, which is what Nevada passed.

Or am I mistaken, and these are the new PERSONAL collection limits?
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Kelly Mc
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Kelly Mc »

Hi Chris, yes it reads clear from all the major articles that it is an all out ban, but I was reading what Ernie had posted which was Jason Jones' original recommendation and I thought of it in those terms, (if I am not wrong in some detail of what Ernie posted)

I read it in an interior way as being well, kind of astute in that if people are wanting to have or commerce those guys, they would actually have to be motivated enough to work to produce/perpetuate the "goods" they want to sell or use. In my mind the number of animals seemed right for that, especially the snakes, and it seems that he was aware of the non-marketability of the lizards other than the window dressing whim-buy lizards some pet stores will offer, with lizards that are common, but really are not suitable or meet the expectations of the GP mainstream consumer. Herpetoculturists would only be interested in many of those as feeders.

I could be mistaken but thats what I thought. Im sure to be corrected if I am.
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Kelly Mc
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Post by Kelly Mc »

50 sagebrush and 50 sceloporus, 50 Uta etc is not enough for lucrative retail chain store distribution but it is enough for a personally collected herpetoculture feeding paradigm for snakes that eat lizards as juveniles. Not many people keep full on to adulthood lizard specialists.

Thats what I was thinking of when I read the listed animals and numbers. Perhaps I was over thinking it.
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Kelly Mc
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Re: State pushes to tighten wild reptile collection rules-Ne

Post by Kelly Mc »

Sometimes Ernie describes and critiques killing Burmese pythons in a way that makes me think he cares about them, sees it as unnecessary and has referred to them with some warmth.

He vehemently hates some agencies and biologists, and commits counterproductive slurs about them. He is clearly very angry.

Richard Hoyer seems angry too, referring to people as incompetent over and over again because they dont do what he thinks they should do. But his disconnect from the welfare and consequences of living reptiles is something i find chilling, it doesnt seem healthy and has destroyed my natural tendency is to genuflect to someone in his standing.
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