[... 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]