October 21, 1992

Dr. Tom French
Mass Division of Fisheries & Wildlife
100 Cambridge St
Boston MA 02202

Dear Dr. French,

A few months ago (July, 1992) you asked me to review the list of reptiles and amphibians that require a permit in the state of Massachusetts in order to determine if the status of any of the currently listed animals has changed such that they could be considered candidates for removal from that list. I made some inquiries within the New England Herpetological Society and located a number of people who were interested in undertaking such a review. Three groups met to discuss the list: one group for lizards, one for snakes, and one for turtles. It was the unanimous opinion of everyone involved that permits should continue to be required for all crocodilians.

We observed two ground rules: 1) Massachusetts has an intrinsic right to regulate any native reptile and amphibian, no matter what a committee member might think, and so native animals were not discussed, and 2) All venomous animals should require permits. I draw no distinction between venomous and so-called “venomoid” animals (reptiles with their venom glands extracted surgically).

The accompanying document details the recommendations of the various committtees. We hope the recommendations address some of the concerns or complaints voiced by our members, while also being acceptable to the state. At the minimum, each group has compiled a list of those animals that we feel definitely should be removed from the permit list, but we also hope that you will consider seriously adopting some of the broader recommendations. Our Society helped compile the original permit list 17 years ago, and, given the great advances in captive care for reptiles and amphibians in the last few years, we thank you very much for the opportunity to make recommendations about some much-needed changes. If you need clarification on any of the points in the recommendations or further documentation of any of the references, please don’t hesitate to call me.

Sincerely,

David Kirkpatrick,
Secretary,
New England Herpetological Society