The International Betta Congress is an international organization of Betta fanciers with approximately 700 members. We are opposed to HR 669, the Nonnative Wildlife Invasion Protection Act, and ask you to join us in our opposition.

Many of our members are involved in the IBC’s Species Maintenance Program, which seeks to set up captive breeding of the various species of the genus Betta. There are currently over 70 known species, several of which have not yet been scientifically described. New species are discovered on an ongoing basis and a fish thought to be extinct in the wild was recently rediscovered on the Indonesian island of Java. Maintaining a species in captivity and keeping it true to its wild form requires that one trade fish with other breeders to maintain its genetic diversity and to avoid the deformities that may develop from excessive line-breeding. It is also desirable to add wild fish to the breeding program occasionally if possible in order to ensure continued genetic diversity within the population. A number of Betta species are threatened or endangered in the wild, primarily due to habitat destruction. It is thus critically necessary that we maintain these species in captivity so that they do not become extinct. Further, it is our hope that some of these species may be reintroduced into the wild if their habitat can be saved. The passage of HR 669 could result in our inability to breed our fish and to exchange fish with other breeders as well as to import new stock or export the fish to repopulate an area of their habitat which has been saved or recovered.

Another potential problem with HR 669 in reference to species maintenance programs is the requirement that each unlisted species be studied prior to its being placed on the approved or banned list. The cost of this may be borne by the person or entity wishing to import the species. We are a group of hobbyists and fish that are part of the SMP are traded, not sold, so it would be difficult if not impossible for us to cover the costs involved in studying the potential environmental impact of each species. The provisions of HR 669 require the USFWS to study the potential impact of all known species in the pet trade and to create a list of approved and banned species within 3 years of its passage. This is a monumental task and one for which no additional staffing or funding is provided under the bill. We greatly fear that animals will be added to the list at family level in order to speed the process. If that is in fact the case, Bettas may be banned on the basis of one or a few species in the family which have the potential to become established in the US. If the list is compiled at genus level, another potential problem is how to handle species whose genus has been changed. As it currently stands, there are a number of species complexes with the genus Betta. It is expected that when a thorough review is completed these species complexes will be raised to genus level, resulting in a situation in which a species which may be approved under one scientific name will not be on the list under its new name. That will in all likelihood result in the inability to import, breed or ship these species until the lists are updated to reflect the name changes. Another problem is how to list known species which have not yet been scientifically described. How does one refer to these species in order to add them to a list?

We agree that certain species may be inappropriate for the pet trade but current law already provides a mechanism to prevent the introduction of nonnative wildlife. The Lacey Act List of Injurious Wildlife is in place in part to keep certain taxa out of the pet trade. Rather than circumventing the Lacey Act by establishing an approved list of species, a better approach would be to increase the funding and speed up the review process for addition to the List of Injurious Wildlife under current law. Current law also includes provisions for the CDC and APHIS to stop trade in potentially injurious species, as they have done with potential carriers of the monkey pox virus and tortoises known to carry Amblyona ticks, which are vectors of heartwater, a noncontagious infectious disease affecting cattle, sheep and goats.

Because many species are only potentially invasive in certain states whose climate is similar to their home range, this issue is better left to the states with the Lacey Act as the overriding law. This is the state of affairs under current law. There are many species that are illegal in states such as Florida, California and Hawaii that are legal to keep in states such as Pennsylvania, Illinois and Montana and that is reflective of the ability of those species to survive in those states. States have taken a variety of approaches to prevent the introduction of potentially invasive species, from permit processes to the banning of certain species. Some states have also acted to prevent the introduction of species that are native to other states in the US. The federal government would not have the ability to take this action.

Please join us in opposition by writing a letter to, or calling, your congressman to express your opposition to HR 669. In addition to contacting your own congressman, write letters to the members of the House Natural Resources Subcommittee on Insular Affairs, Oceans and Wildlife, which will consider this bill in a hearing on April 23, 2009.

Mark I. Denaro
President
International Betta Congress

YouTube Video Against HR669