Open letter to the European Commission DG Environment – CITES Team
cc RPA Europe
Re: Preliminary findings of the EU study assessing the added value and feasibility of an EU-wide positive list.
To Mr Varhelyi - EU Commissioner - Animal Health & Welfare,
On behalf of Responsible Reptile Keeping’s European and global membership, we express deep concern over RPA’s June 10th presentation on the feasibility of an EU-wide positive list.
Please see our attached open letter, which will be circulated tomorrow. It highlights the urgency with which RPA must address the major legal, scientific, economic, ecological, and welfare issues these lists pose, including:
Current positive lists have failed
Positive lists are unenforceable
Positive lists curtail science advancement
Positive lists make dispersal of knowledge and best practices impossible
Positive lists harm conservation
Positive lists are unnecessary due to existing laws
Positive lists are unnecessary as there is no significant problem to solve
Positive lists create poor welfare, eliminating access to vets and expert help
Positive lists promote illegal wildlife trade
Positive lists send keepers underground
Positive lists cause harm to mental health
Positive lists cause harm to the economy, here and in other countries
Positive lists are plagued by legal issues
Positive lists create political unrest
Positive lists are an unjustified curtailment of rights
Positive lists are disproportionate and unfair
We stand ready to support science-based policymaking and can provide strong evidence for our position. To this end, we have prepared a detailed response to guide RPA’s future work, which will be sent to them and the Commission shortly.
Ignoring expert input leads to policy failure, and regulation without stakeholder support will not succeed.
In short, positive lists are alarmingly unworkable and will face firm opposition.
Tony Wigley
Co-founder of Responsible Reptile Keeping