[... the text of what I sent to the subcommittee members:]

When has draconian legislation that should have been based upon
science but was not based upon science not backfired? Can't think
of an instance? Neither can I.

With HR 669 you could once again be set up for further back-pedaling
that would require later corrective Bills if the wording encompasses as
many species as it currently does. Nor does there seem to be logical,
scientific reasoning behind the choices of which animals to consider
potentially invasive species vs. which to not label as such.

I will illustrate this with the domestic ferret, a cousin of the
playful otter, and an animal which is actually safer than its more
distant cousins in Order Carnivora, the domestic cat and domestic dog.

Domestic ferrets have been domesticed since perhaps as early as the
ancient Greeks, and certainly as early as the Ancient Romans. Julius
Caesar had them taken to Malta to help hunt rabbits when that Island
was invaded by European rabbits which live in communal warrens. Unlike
domestic cats and domestic dogs, the domestic ferret is actually a
pretty poor hunter. In fact, their wild cousin which is native to the
U.S., the Black Footed Ferret, is also a poor enough hunter that it
requires large colonies of prairie dogs to feed itself. So, how did the
Maltese tackle their rabbit problem? They did not turn the ferrets
loose as they would have done with cats or dogs. Instead, they used the
ferrets in the same way they still are used: to scare the rabbits from
the borrows. Then the rabbits are either caught in nets or dogs are
used to chase them down. You can find excellent illustrations from
hundreds of years ago in
http://www.doctorbeer.com/joyce/ferrets/frhistpg.htm
which will also show you some pet ferrets from the time.
http://www.veterinarypartner.com/Content.plx?P=A&A=496
will also prove useful.

Would you like to know of a situation right here in the United States
in which people tried to control imported European rabbits that had
formed warrens by turning loose ferrets which failed? Just look at
San Juan Island, Washington. The ferrets survived only a short while,
decades ago. The rabbits are still there. In fact, the National Parks
Service wanted to use extreme measures to rid national land there of
the rabbits but the locals on the island managed to stop them because
native predators, especially eagles, owls, and foxes, have discovered
that the rabbits make for fine meals.
http://www.nps.gov/sajh/naturescience/prairie-restoration-project.htm
 Nor is that the sole place that people tried to establish domestic
ferrets in the U.S. In past centuries several attempts in Ohio failed,
per historical references I have encountered but sadly could not find
for this document.

Domestic ferrets have been helping Americans since the days when we
were all colonies, which is why they are the mascot of the
Massachusetts Colonial Navy. Our seamen used them in conjunction with
cats to tackle the rats that infested ships. The cats could not go into
the borrows, but the ferrets could.
<http://books.google.com/books?id=CSFN5H8RSaEC&pg=PA12&lpg=PA12&dq=ferrets+%2BMassachusetts+Colonial+Navy&source=bl&ots=Mb6XrOMMW4&sig=0SpdsQm_Eselkth3K_7g5BMAlp4&hl=en&ei=GorvSfjFLZDMMKbLEQ&sa=X&oi=book_result&ct=result&resnum=3>

Ferrets were often used by ratters in this country right up to the time
when poisoning took over as the prevalent mode of rodent control. The
ferrets chased the rats from burrows and then traps or terriers were
used to collect them. Terriers also have a long history of being
specially bred to serve as one leg of rodent and rabbit control. Think
of the ferrets like the beaters who scare quail for others to shoot.
The terriers are the marksmen.

To this day the abilities of ferrets to go down tunnels have served
other functions. Even the federal government has benefited. The
Harrisons used them in the White House in conjunction with dogs and
cats to rid the building of a severe rodent infestation. The Air Force
and some federal building construction crews used them for carrying
wiring trailing from harnesses in order to lay wiring in tight spaces
for reduced cost and faster service. The National Labs used a ferret
in Fermi Lab to clean a collider tube before use. She trailed brushes
from a harness.
<http://www.firstladies.org/curriculum/educational-biography.aspx?biography=24>
http://www.af.mil/news/airman/1199/y2ksb.htm
http://findarticles.com/p/articles/mi_qn4191/is_19991002/ai_n9961723/
<http://www.time.com/time/magazine/article/0,9171,799464,00.html?promoid=googlep>
http://history.fnal.gov/wildlife.html#tiny
http://history.fnal.gov/felicia.html
See the playfulness: Ê
http://www.youtube.com/watch?v=28qew8QfTn0

Now you will ask about their wild relatives, the polecats, and about
the New Zealand situation in which fur farmers let polecats and
polecat-ferret crosses free. Yes, they have proven to be predators for
the most defenseless of the ground nesting birds. Yet, you will
remember that our birds here -- including ground nesters -- have not
had this same problem. Why? Because the ones on New Zealand did not
already have predators to which they had adapted. Ours have already
adapted to better predators. In fact, in New Zealand, depending on the
location, a range of other introduced animals have been worse predators
than ferrets or even polecats (which they tend to lump together in
reports). In some places dogs are the biggest problem, in others rats
are, in still others hedgehogs, cats, or stoats are the main culprits.
The most recent study on this regard can be found described here:
http://www.stuff.co.nz/national/2355285/Prickly-problem-uncovered

The humble hedgehog has been outed as public conservation enemy No 1
near the Aoraki/Mt Cook National Park. More than half of the 5029
predators caught over four years, across 20,000 hectares of the Tasman
riverbed, were hedgehogs. "They're very underrated," said Twizel
biodiversity programme manager Dean Nelson, of the Department of
Conservation. ... The surprisingly adaptable creatures, introduced to
New Zealand in the late 19th century, were found as high as 1000 metres
above sea-level. Nelson said the prickly creatures ate birds eggs but
it was not known whether they carried off young birds. They also ate
weta, beetles, grasshoppers and even lizards. ... A two-and-a-half
year study by Landcare Research, published in 2003, bemoaned the fact
that stoats, ferrets and possums got all the attention as predators.
"They are like the bad guys in balaclavas during a bank heist,"
Landcare Research scientist Dr Chris Jones said at the time.
"Meanwhile, hedgehogs are the guys in the background, quietly opening
the safe." ... About 1100 traps were laid from Whale Stream up to, and
including, part of the national park. Hedgehogs and stoats were 75 per
cent of the trapped predators. Wild cats featured more prominently than
possums or ferrets.

How are ferrets' wild cousins, the European Polecats, doing as
predators in their own native areas? Well, actually, in much of their
range they have been having problems because of a native U.S. predator,
the American Mink. American Minks turn out to be far better hunters, so
in Britain, France, Spain, etc. there are currently efforts to try to
rid themselves of mink that were released from fur farms. Perhaps that
is yet another reason that unlike domestic cats and domestic dogs,
domestic ferrets have never established wild populations in our nation
despite being here for hundreds of years, for ratting, for pets, and
for fitch fur. We simply already have native predators who are far
better hunters. The Vincent Wildlife Trust may be the fastest way to
get that information. You can begin with
http://www.vwt.org.uk/species/polecat.php and their contact data.

So, why does it make sense to federally permit domestic cats and
domestic dogs which do form feral populations but to treat domestic
ferrets -- which have not formed feral populations in hundred of years
here -- as if they could do that when they have repeatedly failed to
do so?

You will probably say that such bigotry makes sense because there are
so many cats and dogs. Well, 5 years ago Ken Wells of the Wall Street
Journal pointed out on the Leonard Lopate show on WNYC that U.S.
commerce involving ferrets added up to at least two billion (yes, with
a "b") dollars ($2,000,000,000.) of the then thirty-two billion spent
on pets and their products. Furthermore, the American Ferret
Association estimates that the current number of pet domestic ferrets
has increased since then to between 8 to 10 million animals (10,000,000
ferret pets). There are quite a few jobs tied up in this, and a huge
number of families.

Why do people enjoy ferrets as pets? They are smart, loving, and
playful. Downsides? They and their care are expensive, and they do
tend to require a lot of maintenance.

In fact, my own life was saved by one of our current ferrets, Hilbert,
when our furnace malfunctioned. Although I was half passed out he
managed to gently rouse me so that i could turn off the furnace and air
our home. I guess that is not a surprise when you recall that they are
members of Carnivora like dogs and cats, and are pretty close cousins
of otters.

I've also known people who used ferrets to let them know in time to
take medications and lie down when they were about to have seizures,
known others whose ferrets have been used for nursing home and school
interaction animals, known parents who used ferrets to open the world
for their autistic children, and others for whom ferrets provided other
essential services, as well as having read of at least 5 cases in which
family ferrets alerted people in time to escape fires.
http://www.extremeweezils.com/ewfriends.html#cerino
<http://www.smallanimalchannel.com/media/critter-news/legal-news/ferrets-cause-eviction.aspx.pdf>
http://www.modernferret.com/pressreleases/sean.html
<http://en.allexperts.com/q/Ask-Veterinarian-700/Ferrets-continuing-care-facilities.htm>
http://news.bbc.co.uk/2/hi/uk_news/england/1913455.stm

Now, you will ask about health issues such as rabies, zoonotic diseases
and bite rates.

Last first. Their serious bite rates were studied by Dr. Freddie
Hoffman, a pediatrician, and they have a serious bite rate that is
similar to pet rabbits, a rate that is about 1/200th that of dogs
***PER CAPITA PET***. "Ferrets  -  Pet of Nineties?" can be found
in "FDA Veterinarian", May/June 1991, Vol. VI, Number III.

Nor is rabies a problem. Although domestic ferrets can contract
rabies if exposed their chances of exposure as indoor pets are low.
Furthermore, they have had an effective rabies vaccine which was
sufficiently proven by studies and met federal approval for use in
ferrets before 1990. Then, later after multiple careful research
studies in conjunction with the Rabies Division of the CDC it was
established over ten years ago that ferrets are so safe that they can
have the same quarantine time after incidents as cats and dogs can
have. That comprehensive work led to the the National Association of
State Public Health Veterinarians altering the Compendium for Rabies
Control and Prevention to treat ferrets as the reasonably safe animals
they are. I suggest such experts as Dr. Charles Rupprecht, head of the
CDC Rabies Division, and the rabies experts of the NASPHV as resources
or witnesses.
http://www.cdc.gov/rabies/
http://www.nasphv.org/Documents/RabiesCompendium.pdf
Did you know that despite their thousands of years as companion animals
there is not one recorded instance of anyone ever contracting rabies
from a ferret? Try saying that about dogs or cats. For that matter,
even try saying that about horse, cattle, or sheep.

Now, zoonotics. Zoonotics are diseases that animals share with humans.
Primates and rodents can have quite a number of the same diseases as we
human do. Other species have fewer, though there are some, for example,
poultry, pigs, and ferrets are among the types of animals that can also
get influenza. Luckily, ferrets share very few illnesses that humans
get, and usually with the ones they do, such as influenza the situation
is one of humans infecting ferrets rather than vice versa. Did you know
that there are more zoonotics that dogs and cats get than ones that
ferrets get, and that at least most, perhaps all, of the serious ones
ferrets get are also gotten by dogs and cats?
Page with a note on ferrets is 428:
http://www.nasphv.org/Documents/VeterinaryPrecautions.pdf
Scroll to the charts:
<http://www.defra.gov.uk/animalh/diseases/notifiable/rabies/pdf/qvra-rabies.pdf>
http://www.anapsid.org/chomel.html
from a veterinarian:
http://exoticpets.about.com/od/healthandsafetyissues/f/zoonosis.htm
This resource is not primarily of zoonotics but does give an overview
of diseases by species:
http://focosi.altervista.org/veterinarymedicine_carnivora.html

Are ferrets right for every person or every locale? No, certainly not.
Do ferrets pose a risk for our nation? Again, no, certainly not. Why
list them as if they did? It makes no sense and is incredibly unfair
to a great many citizens.

Pets are good for human health, both mental and physical. My husband is
allergic to cats and horses, while I am allergic to dogs and less so to
cats. Ferrets give us a wonderful option.

I can see good reasons to pursue the legislation, but NOT as written.
The divisions of acceptable and unacceptable animals need to be based
upon the evidence rather than in the form that currently exists.
Obviously, including ferrets in the grouping that is listed as
potentially dangerous non-native animals lacks merit, and that may well
be the case for a range of other animals. On the other hand, preventing
private people who do not need primates to help with handicaps from
having monkeys, apes, or prosimians makes all the sense in the world.
There certainly are other animals also in that category. Meanwhile some
other animals may pose risks in certain locales but not in others, for
example, some types of tropical fish that can live in warm waters but
do not survive in the north, such as guppies. Of course, the states
already try to address those local issues on their own.

With thanks for your time and consideration; respectfully,

[Posted in FML 6311]