Arthroverts
Arachnoking
- Joined
- Jul 11, 2016
- Messages
- 2,463
Hello all, some of you may have seen/heard of @The Mantis Menagerie's awesome work with the USDA/APHIS on matters of legality as it pertains to insects (mainly native beetles) and exotic millipedes. In late 2019/early 2020 I decided to follow his lead and apply for four PPQ 526 permits; two for isopods and two for millipedes. I will discuss the millipede permits here, but not the general application process.
My millipede permits were much more ambitious than The Mantis Menagerie's (TMM for simplicity), simply by number of species/genera/families involved, and therefore I was a bit worried that I had maybe overdone it (later I realized I messed up and didn't include enough species/genera/families, ha ha). TMM reassured me however that this shouldn't be a problem, as the APHIS officials consider each species for what it is and whether it is appropriate for your level of containment. So, I sent it off, and began waiting. About a month or two later, I received a message back from the APHIS ePermits program and was asked to provide information and pictures relating to my "containment facility", which is a bedroom, as well as the Standard Operating Procedures. This was a part in the journey that neither of us expected, and TMM had not encountered (as far as I know this was not something he had to fill out). Then again, the species on his permits were carefully selected so as to avoid having to set up a "containment facility", while for myself, in my excitement, I had given less thought to the idea. I was given thirty days to respond, otherwise the application would be voided. Needless to say I ended up turning it in on the last day, after quickly tidying up the room and taking pictures of everything in it, including the enclosures I was planning on using; it was not your standard containment facility. A large bed occupied part of the room, book cases were in nearly every corner, multiple racks sprawled with enclosures and aquariums, plus a desk and clothes closet/drawers, amongst other things. I have added my Standard Operating Procedures below, based off the framework provided by APHIS, which were typed hurriedly but still with an attempt of professionalism.
After sending this off I was more concerned than ever, as this was new ground. Another month or two passed, and much to my surprise, I found that the permit had been approved with only one species being rejected (which was fine because it was a duplicate, incorrectly spelled name from the APHIS database)! All that was left to do was accept the permit along with the guidances that came with it (I have also attached the guidances below), which was done promptly. And just like that, I was cleared to acquire, keep, and breed around 60 species/genera/families of exotic millipedes. The catch: they had to come from sources within the United States of America (and only the lower 48), Puerto Rico, and the US Virgin Islands. Now those last two are fantastic because quite a few species I had applied for occur naturally there (like Anadenobolus arboreus), but for species that are not yet in the US hobby and are not found on those islands, this is a problem. Hence the aforementioned 2nd permit, which would allow me to receive all the same species from Europe, Asia, Oceania, and the rest of North America (later I realized I should have included South America). In a nutshell, you have to get a permit for intrastate movement of the permitted species and one for international movement of the permitted species.
I am still waiting on that 2nd permit to clear me for international shipments; if it goes through, it will be an amazing development for the US millipede side of the hobby. My hopes aren't too high considering it has taken this long, but then again, I was blessed unexpectedly with receiving the intrastate permit, so maybe...
I must note irregardless that I will still need an import permit from USFWS (Form 3-177) if I receive the import permit and order something from overseas, since I do plan on trading/selling offspring of any species I am successful with with others; if you are only bringing in small numbers of specimens of a few species strictly for your personal keeping (zero distribution), you can qualify for bringing them in for personal use, though this can be risky to do if you bring in more than the USFWS officials think you need. Unlike the PPQ 526 permit the Form 3-177 is not free, and last I remember hearing it was somewhere in the area of $99.
The permit number or a copy of the permit must accompany every shipment I send/receive as well, whether within the US or outside of it. There is a possibility brokers like Reptile Express could ship the specimens so long as I handle things with APHIS and provide my permits to be sent with the package, but this has not been looked into further.
Irregardless, having this permit opens up new opportunities, while also limiting some others. Even if I don't receive the international import permit, having the intrastate permit allows me to deal with willing museums and bug zoos, and with other enthusiasts like TMM (yes, I have already contacted him about his Thyropygus pachyurus), which could allow me access to species available to hardly anyone else (case in point: TMM's T. pachyurus).
However, this also means I am limited in who I can sell/trade to. I can still purchase from anyone within the US, but all sales made by myself must be kept strictly to those who are also permitted for the species in question (I could, for example, buy/trade for any species that TMM is permitted for since I applied and was cleared for all those species, but the reverse is not true), I must keep record of the transaction, and I must send those records to APHIS by January 31st of each year (I am still figuring out how to do that). I also must maintain the containment facility in good order and adhere to all the guidances and SOPs I have given myself, and to be prepared for an inspection at any time within reasonable operating hours. I do not expect to be inspected, but the possibility remains. I will be honest and say that it has been a bit of a change, and I am still struggling to keep with certain standards and guidances (i.e the door is to remain closed at all times), but overall I would say it is completely worth it for the avenues that have been opened to me. I have yet to have received any additional permitted specimens, but I am continuing to develop my connections and I hope to have acquired some new species before the year is out.
All of that's to say that the more of us who get permitted, the more networking can be done and breeders there will be for very rare species; I see the possibility of reviving the olden days of the US millipede keeping side of things when exotic species were plentiful. And who knows? As TMM pointed out, if enough of us do it, the wave of paperwork might make the USDA/APHIS deregulate them as they should be (in my opinion). However, the USDA/APHIS entomologists who process the permits have been incredibly helpful and kind, explaining things to both myself and TMM, and likely many others; considering the permits are free and the amazing service offered, I would say the PPQ 526 might be the easiest permit for you to get, so long as you know what to apply for.
I post this in hopes of spurring further interest in this new-found avenue to acquiring rare species, both for conservation purposes and just for fun. I am currently probing the possibility of attempting permits for roaches and native beetles as well, and eventually seeing what might be done for more exotic insects such as carnivorous katydids and some exotic beetles. If we as enthusiasts are successful in continuing to pursue the legal side of things, it may take away the grayness of our beloved passion for invertebrates and bolster what we do in the eyes of the USDA/APHIS, and beyond.
I welcome any questions, comments, suggestions, etc. Both The Mantis Menagerie and I are available to answer.
Many thanks,
Arthroverts
My millipede permits were much more ambitious than The Mantis Menagerie's (TMM for simplicity), simply by number of species/genera/families involved, and therefore I was a bit worried that I had maybe overdone it (later I realized I messed up and didn't include enough species/genera/families, ha ha). TMM reassured me however that this shouldn't be a problem, as the APHIS officials consider each species for what it is and whether it is appropriate for your level of containment. So, I sent it off, and began waiting. About a month or two later, I received a message back from the APHIS ePermits program and was asked to provide information and pictures relating to my "containment facility", which is a bedroom, as well as the Standard Operating Procedures. This was a part in the journey that neither of us expected, and TMM had not encountered (as far as I know this was not something he had to fill out). Then again, the species on his permits were carefully selected so as to avoid having to set up a "containment facility", while for myself, in my excitement, I had given less thought to the idea. I was given thirty days to respond, otherwise the application would be voided. Needless to say I ended up turning it in on the last day, after quickly tidying up the room and taking pictures of everything in it, including the enclosures I was planning on using; it was not your standard containment facility. A large bed occupied part of the room, book cases were in nearly every corner, multiple racks sprawled with enclosures and aquariums, plus a desk and clothes closet/drawers, amongst other things. I have added my Standard Operating Procedures below, based off the framework provided by APHIS, which were typed hurriedly but still with an attempt of professionalism.
After sending this off I was more concerned than ever, as this was new ground. Another month or two passed, and much to my surprise, I found that the permit had been approved with only one species being rejected (which was fine because it was a duplicate, incorrectly spelled name from the APHIS database)! All that was left to do was accept the permit along with the guidances that came with it (I have also attached the guidances below), which was done promptly. And just like that, I was cleared to acquire, keep, and breed around 60 species/genera/families of exotic millipedes. The catch: they had to come from sources within the United States of America (and only the lower 48), Puerto Rico, and the US Virgin Islands. Now those last two are fantastic because quite a few species I had applied for occur naturally there (like Anadenobolus arboreus), but for species that are not yet in the US hobby and are not found on those islands, this is a problem. Hence the aforementioned 2nd permit, which would allow me to receive all the same species from Europe, Asia, Oceania, and the rest of North America (later I realized I should have included South America). In a nutshell, you have to get a permit for intrastate movement of the permitted species and one for international movement of the permitted species.
I am still waiting on that 2nd permit to clear me for international shipments; if it goes through, it will be an amazing development for the US millipede side of the hobby. My hopes aren't too high considering it has taken this long, but then again, I was blessed unexpectedly with receiving the intrastate permit, so maybe...
I must note irregardless that I will still need an import permit from USFWS (Form 3-177) if I receive the import permit and order something from overseas, since I do plan on trading/selling offspring of any species I am successful with with others; if you are only bringing in small numbers of specimens of a few species strictly for your personal keeping (zero distribution), you can qualify for bringing them in for personal use, though this can be risky to do if you bring in more than the USFWS officials think you need. Unlike the PPQ 526 permit the Form 3-177 is not free, and last I remember hearing it was somewhere in the area of $99.
The permit number or a copy of the permit must accompany every shipment I send/receive as well, whether within the US or outside of it. There is a possibility brokers like Reptile Express could ship the specimens so long as I handle things with APHIS and provide my permits to be sent with the package, but this has not been looked into further.
Irregardless, having this permit opens up new opportunities, while also limiting some others. Even if I don't receive the international import permit, having the intrastate permit allows me to deal with willing museums and bug zoos, and with other enthusiasts like TMM (yes, I have already contacted him about his Thyropygus pachyurus), which could allow me access to species available to hardly anyone else (case in point: TMM's T. pachyurus).
However, this also means I am limited in who I can sell/trade to. I can still purchase from anyone within the US, but all sales made by myself must be kept strictly to those who are also permitted for the species in question (I could, for example, buy/trade for any species that TMM is permitted for since I applied and was cleared for all those species, but the reverse is not true), I must keep record of the transaction, and I must send those records to APHIS by January 31st of each year (I am still figuring out how to do that). I also must maintain the containment facility in good order and adhere to all the guidances and SOPs I have given myself, and to be prepared for an inspection at any time within reasonable operating hours. I do not expect to be inspected, but the possibility remains. I will be honest and say that it has been a bit of a change, and I am still struggling to keep with certain standards and guidances (i.e the door is to remain closed at all times), but overall I would say it is completely worth it for the avenues that have been opened to me. I have yet to have received any additional permitted specimens, but I am continuing to develop my connections and I hope to have acquired some new species before the year is out.
All of that's to say that the more of us who get permitted, the more networking can be done and breeders there will be for very rare species; I see the possibility of reviving the olden days of the US millipede keeping side of things when exotic species were plentiful. And who knows? As TMM pointed out, if enough of us do it, the wave of paperwork might make the USDA/APHIS deregulate them as they should be (in my opinion). However, the USDA/APHIS entomologists who process the permits have been incredibly helpful and kind, explaining things to both myself and TMM, and likely many others; considering the permits are free and the amazing service offered, I would say the PPQ 526 might be the easiest permit for you to get, so long as you know what to apply for.
I post this in hopes of spurring further interest in this new-found avenue to acquiring rare species, both for conservation purposes and just for fun. I am currently probing the possibility of attempting permits for roaches and native beetles as well, and eventually seeing what might be done for more exotic insects such as carnivorous katydids and some exotic beetles. If we as enthusiasts are successful in continuing to pursue the legal side of things, it may take away the grayness of our beloved passion for invertebrates and bolster what we do in the eyes of the USDA/APHIS, and beyond.
I welcome any questions, comments, suggestions, etc. Both The Mantis Menagerie and I are available to answer.
Many thanks,
Arthroverts
