May 10, 2002
Division of Management Authority
U.S. Fish and Wildlife Service
4401 North Fairfax Drive, Room 700
Arlington, VA 22203
RE: Potential Species Proposals, Resolutions, Decisions, and Agenda Items the United States is Considering
Submitting for Consideration at CITES COP12
To whom it may concern:
The California Turtle and Tortoise Club is the world's oldest turtle hobbyist organization and the largest
such organization in the United States. Since 1964, the Club has worked to preserve turtles and tortoises
through its conservation, welfare, and education programs. On behalf of the Club's Executive Board, its 14
Chapters and Branches, and its more than 2,000 members, we are writing to urge you to submit the United States
Fish and Wildlife Service's recommendations to include certain Asian freshwater turtles and tortoises in
Appendices I and II and to include North American softshell turtles (Apalone spp.) in Appendix II for
consideration at CITES COP12.
The United States is a major partner in the international turtle trade, with annual exports alone averaging
8-10 million live turtles. Given the enormity of this commerce, we believe that it is the duty of the US to take
a leading role in promoting responsible trade in chelonians of all types.
There is abundant evidence that the current levels of harvesting of Asian freshwater turtles and tortoises
for the food, pet, and medical trades are not only unsustainable but have already placed several species in
jeopardy. The Eighteenth Meeting of the Animals Committee in San José, Costa Rica, 8-12 April 2002 reviewed and
accepted reports on Cuora ambionensis, Cuora flavomarginata, Cuora galbinifrons,
Lissemys punctata and Pyxis planicauda. Some of the data in those reports reflects the work of
California Turtle and Tortoise Club members. At the very minimum, the US should co-propose listing these species
in Appendices I and II as recommended by the FWS. The US should also firmly endorse the opinion of the FWS and
propose or co-propose the listing, or uplisting where appropriate, of all Kachuga species (this is being
proposed by India), all Chitra species, all Pelochelys species, Amyda cartilagina, all
Cuora and Cistoclemmys spp., all Heosemys species, all Mauremys species, Orilitia
borneensis, Carettochelys insculpta and Platysternon megacephalum.
North American softshell turtles are threatened by habitat loss and modification, and by significant harvest
for the food and pet trade but they are not listed under CITES. The FWS reports that each year since 1993, at
least 10,000 softshell turtles were exported from the United States and in some years the recorded number
exported exceeded 30,000 turtles. The FWS records are inadequate to determine the exact sources and species
involved in this trade which makes it difficult to assess the impact on wild populations. Listing these species
under CITES would remedy this situation by requiring adequate documentation that will allow the assessment of
impacts of this trade on wild populations on an ongoing basis and will thus facilitate adaptive management.
These species occur largely in the United States and the US is the primary interested party. The US should
therefore adopt the FWS proposal to add Apalone spinifera, A. mutica, and A. ferox to
Appendix II.
We thank you for this opportunity to comment on the US proposals to CITES COP 12. We respectfully request
that we be included in any future mailings on this and related matters. Please direct correspondence to Dr. M.
J. Connor, California Turtle and Tortoise Club, P.O. Box 7300, Van Nuys, CA 91409-7300 or by e-mail to <mconnor@tortoise.org>.
Sincerely,
CALIFORNIA TURTLE AND TORTOISE CLUB
Michael J. Connor, Ph.D.
Vice Chair, Executive Board
Marc D. Graff, M.D.
Chair, Executive Board |
