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TURTLE SURVIVAL ALLIANCE

Why the Tortoise Trust cannot support this organization

We publish below the full text of our letter to the TSA. It is self-explanatory. Muliple attempts to get straight answers to straight questions have been made, by various routes. Questions have been asked of TSA Steering Commitee members both in private and in public - all have met with the same response. Silence. Our formal letter (below) was submitted to them on 28 August 2002. It is now Jan 1 2003, and we are still waiting for answers. Individual TSA committee members, and TSA representatives when confronted with these questions on mailing lists have run like scared rabbits rather than attempt to address the issues raised. For several months now, our every effort to get them to deal with these very serious matters has been obstructed at every turn.  We have also recently been informed that NO ANSWERS EVER WILL BE GIVEN.  They will not address these matters, and have subsequently engaged in an on-going campaign to discredit the Tortoise Trust for daring to ask them.

Leaving aside the matters raised in the questions themselves, we really have to ask: is this the way any organization of integrity should behave?

What is the problem here? Why is it so difficult for them to provide straight answers to what in many cases are really very simple questions? Why should it take MONTHS to extract explanations from them? Why should anyone who does try to get answers be met with a barrage of insults, threats and promises that to continue will be "political suicide?"

The TSA claims to be "accountable". In our opinion, that is simply not true. This is an organization where individuals function under a conspiracy of silence. They fail to provide facts, they fail to voice opinions - the one thing that they do actually do is try to supress any disclosures or even discussion of contentious matters. Mr. Darrell Sennecke is supposedly in charge of their "communications". His one positive act in this entire farce has been to ban all discussion of these issues on the Asian Turtle Crisis list!!!!

This has reached the point where in our view, the TSA cannot possibly be considered fit and suitable people to be given responsibility for major turtle conservations efforts.

The total lack of openness and culture of cover-up which in our view pervades the entire organization at the higher levels is absolutely unnacceptable. While many volunteeers have done splendid work on behalf of the TSA, the management problems and utter failure to address the issues highlighted below signifies fundamental flaws in the way in which that organization is both constituted and operates.

We would very much like to support a world-wide effort to conserve chelonia, but we cannot support the TSA until:

a) It provides satisfactory answers and explanations to the questions and issues raised below.

b) We see some evidence of genuine accountability and openness.

Until both of these conditions are fullfilled, we urge our own members to exercise extreme caution in accepting TSA claims, and we urge governmental authorities with responsibilities for seized animals to undertake a full and independent investigation into the TSA before releasing further animals into their care.

Our experience of the TSA has been thoroughly negative. We began by asking a few simple questions informally - when it became obvious that there was an unusual degree of determination NOT to answer these questions, we probed further. The more we discovered, the more concerned we became. We feel that until the TSA institutes major reforms of both policy and practice, it simply does not deserve to enjoy the support of those genuinely concerned with chelonian conservation, and in particular, with animal welfare.

Such a culture of secrecy and denial, and of suppression of dissent, is entirely alien to the definition of genuine accountability. If a conservation organization is unwilling to even explain its policies on euthanasia, for example, why on earth SHOULD anyone support it? More to the point, why should anyone TRUST it?

UPDATE 4 October:

Rick Hudson (TSA chair) has apparently stated he is willing to "talk with us" about these matters. This is a complete nonsense - and he knows it. Formal questions have been put officially to the TSA. What is required is an official, formal, strictly on-the-record written response, not off-the-record, behind-the-scenes informal "conversation". Mr. Hudson apparrently states that he "can explain everything". Fine - then let him do so. Openly, and in public.  There is too much secrecy and behind-the-scenes politics going on in the TSA already. We are certainly not prepared to contribute to more of it.

UPDATE 24 October:

It is steadily emerging that many individuals involved in the TSA are simultaneously involved in trading the very same species that this organization claims to be "conserving". There is clearly a major conflict of interests involved when "conservationists" are also selling, buying and trading the animals that they are supposed to be working to protect. The latest name to emerge in connection with the sale of highly endangered (and high value) Asian turtles is Jim Barzyk - a member of the TSA's steering committee. Mr. Barzyk is best known to us for the quote "you can ask as many questions as you like" - and then refusing to provide one single answer. Even where animals are being legitimately captive-bred, as Mr. Barzyk's undoubtedly are, it is our opinion that direct involvement in the trade in high value, rare specimens is not fully consistent with maintaining an independent position on the governing body of a conservation organization. One of our main concerns with the Turtle Survival Alliance is the mutually beneficial and cozy relationship it positively encourages between commercial dealers and collectors. Commerce in endangered species is widespread within the organization, with animals being sold, exchanged and traded routinely. This is not, in our submission, the hallmark of a genuine conservation organization - instead, it conveys the very clear impression of a rather exclusive flea-market, for members only. While we encourage genuine captive breeding, and have no objection to individuals selling captive-bred stock, we do feel that there are serious dangers when a conservation organization is actually being governed by people involved in the sale of high value, highly endangered species. We call upon all those within TSA who are involved in such transactions to step down from the governing body.  The credibility of the organization as a genuine and independent force for conservation will continue to be undermined while such activities persist.

UPDATE 20 NOVEMBER

We have been assured privately by Anders Rhodin that there is no current official policy of mass euthanasia, and that he personally is totally opposed to any such policy and would not approve it. It is confirmed, however, that elements within the TSA most certainly were considering implementing this policy and actively discussed how best to carry it out. We are at least grateful that it does now appear that this particular policy is dead in the water. It would have been a tragedy for turtle conservation and would have resulted in a public relations disaster.

The Tortoise Trust

LETTER TO THE TURTLE SURVIVAL ALLIANCE

 Gentlemen,

 

As you are aware, I have raised a number of grave concerns that I presently have regarding certain aspects of the policy and practice current within the Turtle Survival Alliance. I am indeed grateful that you have given Lori Green your word that you will now answer these concerns. I would, on behalf of the Tortoise Trust, very much like to be able to endorse and support a global effort to work with threatened chelonia, however, I can only do so if we are entirely satisfied on a number of critical practical and ethical points. I applaud the effort that has gone into forming the Turtle Survival Alliance. Much has been achieved, for which I congratulate you. That said, however, these concerns remain, and progress on other fronts in no way diminishes the need for these specific concerns to be addressed and, if necessary, for certain policies or practices to change.

 

I do not feel that genuine progress can be sustained if we are (any of us) prepared to turn a blind eye to deficiencies or failures. We all make mistakes, and we need to learn from them. Policies too must be transparent and subject to proper ethical scrutiny. Genuine concerns, raised by any means or from any quarter must be properly and honestly addressed.

 

It is my sincere hope that the Turtle Survival Alliance will ultimately prove to have policies and methods that we are able to endorse and support without reservation. While we are indeed pro-conservation, we also feel that the humane and animal welfare aspects cannot and should not be ignored. Both conservation imperatives and humane aspects need to be carefully balanced. One should not be sacrificed on the alter of the other. It is our view that these two aspects are certainly not mutually exclusive, and that it is perfectly possible to reconcile the two in a practical sense that also meets certain minimum ethical standards.

 

The specific concerns that we have are listed below. I apologise in advance for the length of this, but quite a number of separate areas of concern exist. I hope that you will address these in sufficient detail to set our minds at rest, in order that we can overcome the obstacles that cause us to hesitate in supporting the effort you have initiated.

 

I appreciate that an instant reply to such complex issues is impossible, but I would appreciate an acknowledgement that you have received this, and some indication of when a full and considered response will be forthcoming. 

 

Yours truly,

 

Andy C. Highfield

Director - Tortoise Trust

 

 

1. Would the TSA explain precisely what measures it takes to ensure that animals it receives receive an adequate and professional level of husbandry following their confiscation? Specifically, are facilities inspected in any way, or at any time, and is there any mechanism for verification?

2. In the event of it becoming apparent that TSA animals are being maintained in seriously sub-standard conditions, what action would be taken to correct the situation?

3. Has the TSA ever intervened, in any case, where concerns have been raised about the conditions of maintenance, and if so, what action was taken?

4. Would the TSA please comment upon the following report on dietary management at Mr. Weinberg�s premises?

�In the mornings, Weinberg goes to a local grocery store and picks up thousands of pounds of produce trimmings and adds it to hundreds of bread loaves, pies, doughnuts and muffins stocked in a cooler for the reptiles.

"They'll eat anything. They're not real fussy," he said, throwing bread into the ponds and watching as dozens of little heads pop out of the water and swim slowly toward the meal.

With more than 60 species of turtles - as well as a few rhino iguanas, hundreds of green tree frogs and even a two-headed snake - Weinberg said he's been working with the animals long enough to know what each kind requires. �

Does the TSA feel that this is the kind of example of chelonian husbandry its most senior members should be setting? What message does this send out? What action will be taken in this regard?

5. What steps does the TSA take to establish the bona fides of persons entrusted with their animals? Specifically, what kind of criminal conviction or allegation of criminal activity would exclude an individual from involvement or from holding any kind of management post?

6. Is the TSA aware that Mr. Weinberg was specifically named in connection with the alleged laundering of a federally protected species, Clemmys insculpta, via Ohio? This report appeared in Notes from Noah and was widely circulated in Herp Digest.

7. Why should persons concerned about turtle conservation have any confidence in an organization that appoints to its central committee people who have been openly named in connection with unlawful activities involving endangered wildlife?

8. Are any TSA partners involved in the export of turtles from the USA to Asia for any purpose? If so, which persons, which species, and for what purpose?

9. Will the TSA unequivocally and without reservation condemn the export of live turtles from the US to the food markets of Asia?

10. Does the TSA have any view on the humane aspects of exporting live turtles to the food markets in Asia? What action, if any, would be taken against any TSA partner found to be implicated in such trade?

11. There are credible reports of sick turtles being �dumped� into Mr. Weinberg�s open outdoor ponds without receiving adequate veterinary treatment. It is reported that very few, if any, of these animals now survive. Would the TSA please explain exactly what happened and provide numbers and details of species of the animals involved? One report states �The decision was made to "triage", and only animals deemed placeable through AZA homes were treated - the rest received little or no treatment and were dumped in Al Weinberg's ponds, despite clear veterinary evidence of sepsis, dehydration, starvation and the very strong probability of communicable disease transmission to native fauna�.

12. What was the biological and sanitary status of the ponds used to receive the Kadoorie turtles? Had they not been previously occupied by other species? How was cross-contamination prevented? What is the status of these ponds now - how is waste water dealt with, and what risk assessment has been carried out by the TSA regarding the potential to contaminate the Florida habitat with introduced pathogens from Asia? Will these ponds ever be re-used for other species, and if so, how will biological quarantine be maintained?

13. Does the TSA endorse the mixing of species from different continents and localities?  If not, what measures does it have in place to prevent this occurring in holding areas or subsequently, in collections? Specifically, in connection with facilities that are being utilized for commercial purposes, how can mutual cross-contamination with micro-organisms realistically be prevented? How is contagion between open ponds that are in such close proximity prevented?

This is an extremely serious issue, and cannot be ignored, particularly in areas where there are high densities of native chelonia. One mistake in this area could have catastrophic consequences not only for indigenous wildlife but also for human health. Potentially zoonotic diseases have repeatedly been recorded in imported Asian turtles. In my opinion, there can be no compromise over issues of transmittable disease. This is a risk that we should not run. Quarantine protocols must be beyond reproach. It is plain to me that during the Kadoorie operation, there were very grave deficiencies in this area. Frankly, the damage may have already been done, and it could be years before we become aware of it. As an absolute priority, these fundamental errors must never be repeated. I would sincerely hope that the TSA is in full agreement with this position. 

14. If species have been mixed or subject to indirect cross-contamination by potentially pathogenic agents, what impact does this have upon their status as assurance colonies, or upon the potential for them or their progeny as suitable candidates for ultimate release?

15. Would the TSA care to explain why one of their Steering Committee members (Mr. Weinberg again) was actually displaying tanks containing mixed species, from different continents, Asia and North America, at the recent expo in Daytona?

Please comment on the example this sets to other keepers, enthusiasts and supporters who are consistently warned to avoid such practices at all costs. What are they supposed to think when they see a TSA Steering Committee and Confiscation Task Force coordinator doing the very thing they have been repeatedly asked (for very good reasons) to avoid?

16. Please elucidate the policy of the TSA on �triage� / euthanasia. Under precisely what circumstances would turtles be euthanised?

17. Please explain exactly what is meant by the following recommendations of your �Confiscation Task Force� as reported in your meeting minutes:

 

  a) Ability to triage based on conservation value and limited resources.
  b) Ability to provide humane care (including euthanasia) for all animals as determined by their triage evaluation

 

18. Will the TSA give absolute, inviolable guarantee that no healthy, viable turtle would ever be euthanised at their request? If not, does the TSA acknowledge that it foresees circumstances where it would condone the killing of healthy, viable turtles or tortoises?

19. Is it not the case that it has been determined that any euthanasia should be carried out secretly in situ, for example, in Asia,  rather than in Europe or the US, to avoid the resulting negative publicity?

20. Explain the moral and ethical difference between the Swedish government�s euthanasia/slaughter of 1,000 T. horsfieldii a few years ago and any similar action contemplated by the TSA where turtles are found not to possess adequate �conservation value� or where they are determined to be a drain on �resources�.

21. In the event that animals are not considered of adequate conservation value to the TSA or where the TSA regards them as a waste of resources, will the TSA give a binding undertaking that rescue groups will be given the opportunity to step in and save these animals from medically unnecessary euthanasia?

22. Please comment upon the words of Bonnie Raphael, during the TSA Steering Committee meeting of March 9 2002 that the TSA should �Tell rescue groups that TSA is going to euthanize animals unless they take them� and state how this kind of blatant blackmail could possibly be ethically justified? Would the TSA actually carry out this threat?

23. What was the reason for TSA taking the decision to sever existing ties and not to initiate any new ties with HSUS or World Society for the Protection of Animals? Was it not the fact that these organizations would find the proposed euthanasia protocols and continued commercial exploitation of the progeny of confiscated animals as endorsed by the TSA completely unacceptable?

24. While the food markets remain the overwhelming issue for turtles in Asia, in the US and Europe the pet trade plays a not insignificant role in the decline of many species, not to mention their abuse in the process. The TSA has expressed view on the food market situation: what is the TSA position on the role of the pet trade, and the wild-caught pet trade in chelonia specifically? Of special interest would be some explanation as to the direct involvement of TSA committee members and partners in promoting and participating in such trade? I would stress that I believe that a line can be drawn between legitimate, legal herpetoculture involving trade in genuine, sustainable captive-bred stock, and trade involving wildcaught reptiles.

25. Does the TSA not recognize that by permitting animals that are bred from confiscated stock to be sold at market value, and by placing rare and valuable animals under the direct control of private collectors and commercial dealers, this has two very obvious drawbacks: a) There are almost incalculable possibilities for fraud  b) The TSA could be viewed as an excellent �free source� of hitherto unobtainable and prohibited species by those motivated not by any desire to further conservation, but by a desire to expand their collections and turn a profit?

26. Precisely what mechanisms are in place to prevent such abuses, and what spot checks are carried out to verify the results of self-reporting?

27. How many individuals acting as coordinators, committee members or advisers to the TSA have animal-related criminal convictions, and what do those convictions involve? You are clearly in possession of this information, as your published membership forms have requested it from all applicants. I am not requesting disclosure of actual names, merely the statistics.