To whom it may concern;
I am writing to request your consideration in the matter of allowing the Two-toed Sloth
to be included on the unregulated list for wildlife in the State of Colorado. Species:
Choloepus Linnaeus (Linnaeus' Two-toed Sloth) or Choloepus Hoffmann (Hoffmann's
Two-toed Sloth). Family: Megalonychidae, Genus: Choloepus. I would like both species
considered for the list. The two-toed is the only type of sloth that can live in captivity;
therefore, I would not consider the three-toed as an option. In this proposal I will
answer all of the questions necessary to make your determination.
I would first like to stress the fact that Sloths, by nature, are NOT aggressive or
dangerous. They are docile and slow moving. The fact that they are tropical and live in
the rain forest means the Sloth does not have the ability to survive on its own in the
climate of Colorado. In the event they would "escape" or even be let go on purpose,
the Sloth would perish on its own. We don't have their natural food source, nor can
they maintain their own body temperature; therefore the cold temperatures in CO are
not conducive to life for them. In the event they were to escape, sloths move so slowly
that they would be easily recaptured.
They do not mate with any other species; therefore, there is no jeopardy of inter
species mating. They only mate once a year and only have one off spring. Their
gestation is 9 to 11 months and they only mate if their current infant is completely
weaned and on its own. They are solitary animals and very slow, so there are times
when they miss the mating season all together, which is commonly “the dry season” in
the wild.
There is no danger to agriculture or native wildlife as previously stated Sloths cannot
survive out of captivity in this State. They require humidity and warmth in order to
survive. Their natural habitat is the rain forest; CO is not close to that.
Sloths are not dangerous; they are herbivores, so they will not prey upon natural
wildlife, or any animal. In captivity there is a specific diet which can be purchased
online; Marion leaf eater food. You supplement their diet with spring mix lettuce and
sweet potatoes. They also eat carrots, green beans and squash. Sloths can take up to
one month to digest one meal due to their very slow metabolism. There is no danger to
native vegetation as they do not eat enough to make an impact. Not to mention, they
cannot survive on their own.
Sloths do not have any zoonotic diseases. In their natural habitat they are a host to
microorganisms and have multiple bacteria in their fur. In captivity they do not, as they
don't have the same habitat. They have intestinal parasites, again not in captivity. The
parasites are from their natural diet, which they don't eat in captivity. There are several
studies about sloth fur. The belief is that in the wild the fungi in sloth’s fur have
medicinal benefits. The studies believe that their fur contain fungi that could possibly
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one day help in the fight against breast cancer and treat various other diseases. The
studies are still in progress and have a long way to go, but so far the results are looking
favorable. I’ve had a discussion with Dr. Schotman, DVM, who currently has over 10
years experience working on sloths. He has never seen any zoonotic diseases or any of
the natural intestinal parasites that they have in the wild in the captive sloths he’s dealt
with. Please see the attached email from Dr. Schotman, DVM for his added information
on the topic.
The "weediness" of sloths is nonexistent. They are not aggressive, they cannot survive,
let alone thrive in CO. Sloths do not inter breed or adapt to other food sources. The
natural vegetation in CO can be eaten by sloths, but they require a little more nutrients
in order to sustain life, so on their own in the wild would be a difficult task at best.
Finally, I contacted the Departments of Wildlife in Arizona, Utah, Nevada, Wyoming,
Nebraska, Kansas, Oklahoma, New Mexico, Idaho, and Montana, to get their regulations
on sloth ownership. Nebraska is the strictest; they do not allow any wildlife that is
nonnative, so sloths are prohibited. Arizona has them on their restricted list; however,
you can get a special license to own them. Nevada, New Mexico and Wyoming require a
permit to own one, but each agency said the sloth was considered to be not dangerous
or invasive to the natural wildlife, so they would have no problem issuing a permit upon
request. Kansas, Oklahoma, Idaho, Montana and Utah all have no regulations on them
and they can be owned with no restrictions. The only exception is Idaho does require a
health certificate in order for them to be imported. I spoke with the Department of
Agriculture and the state Veterinarian in Idaho and Oklahoma, because an exotic animal
falls under their guidelines for those states. Those departments also said the sloth is not
harmful to the environment and not considered an aggressive or dangerous animal to
own, therefore; there is no regulation on ownership.
In the state of Montana they recently (2005) admitted the sloth to their “domesticated
non regulatory” list. I’ve attached their process in making their decision. As a state,
they form an independent committee comprised of DOW members, veterinary staff,
Department of Agriculture people and citizens. Once that committee researches the
animal in question they make a recommendation to the Commission for or against the
animal. As I previously stated, their recommendation was to make the sloth acceptable
to own in their state. They actually have several people who currently own them now.
There are individuals in Idaho, Kansas and Utah that also currently own the sloth as a
pet.
On a personal note, I work for the only exotic Veterinarian in our city. We deal with the
kangaroos, wallabies, and sugar gliders in town; animals that are currently on the
unregulated list. Those animals can be very aggressive and are often time hard to
handle. The sloth would be very similar to having a hairy box turtle in comparison. As
with any animal, wild or domestic, you should always take care when handling so as not
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to get hurt. You can be injured by any animal if you do not take the appropriate
precautions domestic or otherwise.
This is a link to a brief video (approximately 15 minutes) for “sloth care”. It
demonstrates how docile this animal is and what is required to care for them as
juveniles. As they grow up their care is not as intense, but they will always require
some degree of care.
https://docs.google.com/file/d/0B0b0wm2YibDETy1DeEZXanZSQ1k/edit?usp=drive_web I hope this
helps to clarify their care and habitat in captivity.
In conclusion there are no adverse effects in the State of CO for sloth ownership, only
the benefit of a slow moving, docile, huggable companion that will live a long happy life
with the right environment.
Thank you for your consideration in this matter.
Bibliography:
- San Diego Zoo Library
- Emmons 1990
- Gilmore 2008, 2000
- Merritt 2006, 1985
- Montgomery & Sunquist 1973, 1978
- Ramprashed 1985
- Goffart 1971
- Parra 1978
- Rosenberg & Maliniak 1985
- Nowak 1999
- Taube 2001
- Smithsonian Tropical Research Institute
- Higginbotham, S., et al 2014
- Dr. Tom Schotman, DVM
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CITIZEN-PROPOSED ISSUE PAPER
Date: 08-27-2015
ISSUE: Putting the Two-toed Sloth on the unregulated list for CO
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
See attached
WHO MIGHT BE INTERESTED IN THIS ISSUE? HAVE YOU
COMMUNICATED WITH ANY OTHER INTERESTED PARTIES? WHAT INPUT
HAVE YOU RECEIVED?
I may be the only person interested in this animal as a pet. I’ve not heard
from anyone since I began this endeavor. When I bring it up to people I
know, they’re shocked that anyone would want to own one. That being
said, I live in a smaller community, in the larger cities they may be more
desirable. Everyone that I do tell are thrilled to be able to know someone
who owns one and would love the opportunity to pet one.
ALTERNATIVES: PLEASE INDICATE THE PROBABLE OUTCOME IF THIS
PETITION IS ACCEPTED, AS WELL AS THE IMPACT OF ALTERNATIVES
TO THIS PETITION:
This would allow me to be able to obtain a sloth as a pet. As demonstrated
in my proposal, there are no adverse effects on the current wildlife or their
habitat by allowing the sloth to be unregulated. If we can’t put them on the
unregulated list, I would like it to be considered making it possible for a
permit to be issued to own one.
PETITION PROPOSED BY:
PETITION WRITTEN BY:
DATE SENT TO THE
COMMISSION:
Darcy Sanborn
Darcy Sanborn
08-27-2015
WHO MIGHT BE INTERESTED IN THIS ISSUE? HAVE YOU COMMUNICATED WITH
ANY OTHER INTERESTED PARTIES? WHAT INPUT HAVE YOU RECEIVED?
Recent interest in sloth care and it’s status in the wild is wide spread. People with an
interest in preserving the delicate balance of the rainforest always have a keen interest
in what they can do to preserve it’s inhabitants. Domestic imports of two toed sloths into
the U.S. number 119 annually, most of which go to the private sector. These are the
people most effected by exotic animal regulations. With significant new hurdles now
accomplished, successful sloth husbandry has become something possible to people in
areas of the U.S. previously impossible including Colorado. In an increasing hands on
approach to environmental stewardship, potential, and present sloth keepers want to be
part of the groundwork to preserve this animal by being a member of a network of
keepers with the intent of captive breeding. Only with the participation of qualified
keepers will the captive population of U.S. sloths be developed and available if and
when, the status of the sloth changes. Sloth keepers as well as the scientific community
agree, we are entering the next great era of extinction. We will witness the loss of many
great species. Since the earliest recordings of animal species to present day we have
lost over 50% of the animals that inhabited the earth. Sloth keepers believe in a hands
on approach to rainforest stewardship. So little is known about the habits and
requirements of the two toed sloth that if a significant number of people don’t step in, it’s
future may be threatened. Only by allowing the keeping of sloths in the private sector,
will the accumulation of animals in this invisible Ark be established. When we refer to the
invisible Ark we refer to the vast holdings in the private sector of rare and endangered
animals, legally and responsibly kept. These animals are maintained without state or
federal funds, they require no donations, trusts, or contributions. They are simply
maintained by the focused intent of the private keeper. Although the other keepers I’ve
had communication with are not Colorado residents they have encountered similar
regulations which group sloths as exotic animals that were prohibited or in need of
regulation. With education the state of Utah recently amended their regulations for the
city of Salt Lake to allow a private keeper to obtain a sloth. Other states with climates
more suitable for invasive species from the rainforest allow sloths with simple class 3
permits, including Florida and Texas. As a U.S. citizen one of the inalienable rights I’m
entitled to is the pursuit of happiness, regulations restricting my importing a non-invasive
and harmless animal into Colorado to further conservation stands in the way of my
pursuit of this happiness.
ALTERNATIVES: PLEASE INDICATE THE PROBABLE OUTCOME IF THIS
PETITION IS ACCEPTED, AS WELL AS THE IMPACT OF ALTERNATIVES TO THIS
PETITION:
Allowing the deregulation of two toed sloths in Colorado will show the state’s willingness
to examine and change laws which put unreasonable hardship on animal keepers when
shown evidence of them being non-invasive, harmless and of no threat to native wildlife,
agriculture or residents. Recognizing the benefits of homegrown efforts to preserve
vanishing species by adjusting regulations goes a long way to show the state of
Colorado has a commitment to the needs of it’s residents. Acceptance of this petition
specifically allows the authorized import and keeping of the two toed sloth. An
acceptable alternative would be to allow a permit to be issued without the changing of
the regulations that would exempt the petitioner and allow the import and keeping of a
two toed sloth.
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CLASSIFICATION OF EXOTIC SPECIES
RECOMMENDATION BY THE CLASSIFICATION REVIEW COMMITTEE
COMMON AND SCIENTIFIC NAME:
RECOMMENDED CLASSIFICATION:
TWO-TOED SLOTH (FAMILY
MegalonychidaeCholoepus didoctylus)
UNCONTROLLED
Current Classification and Control
Two-toed sloths are listed on CITES but are not currently listed as endangered.
Environmental Impacts
Two-toed sloths live in equatorial regions of Central America and northern South America and
could not live in Montana if they escaped or were intentionally released. They present no
potential for significant environmental impacts.
Health or Safety Risks
Although seemingly slow moving, sloths can strike fairly quickly with their long forefeet, which
have large, hooked, sharp claws. They also use their teeth effectively, and both means of defense
can inflict severe wounds. There are no known zoonotic diseases associated with two-toed
sloths.
Recommendation
The Classification Review Committee recommends that two toed sloths be listed as uncontrolled
for private possession in Montana. It is not expected that many two toed sloths will be imported
into Montana. This request was generated by an individual who has possessed two toed sloths
for many years and is moving to Montana. The individual has experience and training in the care
of these sloths.
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As a supplier of Two Toed sloths with over 17 years of experience keeping sloths it has
become increasingly clear that the popularity of these gentle animals has increased to a
level of admiration seldom seen in the pet trade. Interestingly the amount of effort to
obtain sloths has not become any easier, if anything it’s become harder. Significant
advancements in the care and husbandry has taken years to achieve, but finally we are
moving in the direction where we can confidently say we can keep this interesting
animal alive and healthy. Only a few years ago the mortality rate in zoo kept sloths was
over 60%. With a more detailed understanding of the diet, temperature and humidity
levels necessary for successful sloth husbandry, sloth care has moved light years
ahead of where it was less than a decade ago. This is mainly because the private sector
has invested so much time breaking the husbandry codes to keep them successfully in
captivity. The next hurtle will be captive breeding, which up to this point has only
occurred sporacticly at best. A few zoos and private keepers have had captive breeding
success and a few more private keepers have had captive births from wild matings. To
advance captive breeding, baby sloths need to be established in captivity and grown for
the 3 to 4 years it will take to reach maturity and selectively bred to eliminate the need
for imported sloths as well as to secure a population safe from environmental
challenges. Conservation challenges of Two Toed sloths include the loss of habitat,
climate change, and hunting for bush meat. Presently listed on the wildlife red list as a
species of least concern, the two toed sloth has largely been overlooked. Understanding
that waiting until a species is in peril is the wrong approach to preserving it, interested
sloth keepers have formed a network of U.S. keepers. Participating in Sloth Blogs,
internet forums, and social media, keepers share experiences and milestones in captive
husbandry. Long gone is the idea that people in the private sector are unable or
shouldn’t be a part of serious conservation involvement. Instead contempory observers
have seen the complete ability of private keepers to not only have success with species
never bred in captivity but significant husbandry milestones achieved that were elusive
to even some of the nation’s top zoos. In the captive breeding of rare reptiles for
instance, the private sector has bred nearly every species of Python in the world, while
all the zoos in the world achieved only a fraction of this success. Why is the question.
The answer is rather simple, and revolves around the dedication of raising a target
species by people participating in an economically driven model of conservation. The
easy access to high end electronics to replicate climate challenges and the information
access to native range climates in a real time setting are just some of the parameters
available to private keepers that contribute to their success and drives the keeper to
constantly seek what others can’t achieve. Add to that the availability of high end zoo
type diets via the internet and the availability to advanced animal veterinarians for
medical care and the scenario is set in motion. Some of the last hurtles for sloth
ownership are states that have passed blanket regulations prohibiting exotic animals to
be kept as pets. Considering the nature of sloth keeping, maybe a new category of
animal care should replace “pets” in this instance, it should be deemed as “animal
stewardship”. Regulations are needed for animals that pose a threat to people and
wildlife, as well as commercial livestock but the non-invasive and harmless nature of
sloths places them in a category best described as harmless. For states with temperate
climates like Florida and Texas where invasive animals are well understood and
regulated they are allowed with a simple license. This identifies where the animals are
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held and gives authority to the wildlife agency to issue cage guidelines and authorizes
inspections to ensure animals are kept properly and humanely. Interestingly in the state
of Florida, which has the most invasive animal problems of any state, the Florida
Wildlife Conservation Commission relies heavily on the private sector for advice, and
involvement with regulations, a relationship that has been beneficial to both the state
and it’s human and non human inhabitants. Utah and Montana are two states that
recently revisited their regulations on keeping sloths and now allow private keepers to
have them. Most other states have provisions in place to allow the keeping of sloths,
recognizing them as a non threat to people and the environment. Simply stated they are
too specialized, too slow and delicate to survive without a educated keeper in almost
any part of the country except extreme south east United States. They pose no danger
to people from disease transfer, have not been known to carry internal parasites and in
most cases could not significantly injure someone unless they were asleep. With all this
in mind it seems that educated lawmakers could only conclude that authorizing sloth
keeping in the private sector certainly should be allowed with oversight.
Pete Bandre
Owner of Incredible Pets Inc.
Melbourne, Fl.
Sent from Mail for Windows 10
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