b) It was noted that the average size of Trachemys scripta elegans on sale was 7.5". Some substantially larger animals were also recorded. It should be noted that this species is sexually dimorphic in terms of shell morphology, males being substantially smaller than females of equivalent age. The average size of female Apalone was 15", although some specimens of 20" were observed. Male Apalone are again smaller, and those observed in this survey had an average SCL (Straight Carapace Length) of 7".

c) This data reveals that the animals on sale were mature adults, and that the vast majority were at least 10 years of age, with some demonstrating clear evidence of ages in excess of 18 years. We would assess the age of some specimens in excess of 25 years. This was further substantiated by scientific analysis of ontogenetic changes in carapace coloration and accutance. One very large Apalone was assessed at 35 years of age. We respectfully point out that this evidence conclusively eliminates any possibility of a "ranched" origin for these turtles. 100% of the turtles encountered during this study, were, in our expert opinion, undoubtedly wild-caught. Ranched turtles can be raised to adult size more rapidly than wild-caught turtles by utilization of high protein, high input feeding regimes, but such animals are readily identifiable and they do not, and cannot, display the ontogenetic features universally observed during this study.

d) All animals revealed normal (non-accelerated) growth patterns. This again is not consistent with a "farm raised" origin, where rapid growth is encouraged for obvious economic reasons. It is patently uneconomic to breed turtles and maintain them for periods of up to 25 years before eventual sale at wholesale rates for what amounts to a few cents per pound.....

e) Some animals revealed evidence of old carapace damage consistent with injuries typical of those seen in wild turtles.

f) Farm-raised Red-eared sliders are produced in very large numbers indeed for export as pets. These animals are typically exported as very young hatchlings, usually of approximately 1" carapace length. We are aware of NO commercial turtle farms which raise animals to maturity before sale. All adult animals held on such farms are invariably of wild-caught origin. Statements by those involved in this trade admit that where adult animals are sold these are not raised from captive-bred stock, but are invariably wild-caught specifically to meet orders for large turtles which the farms themselves for both logistic and financial reasons are unable to produce.

g) Several other species were encountered, invariably 'mixed in' with Red-eared sliders, which are never bred commercially on farms or ranches. These included Graptemys ouachitensis and G. pseudographica (Map turtles). Most disconcerting of all, we encountered the native Californian Western Pond turtle Clemmys marmorata on sale in a food market. The taking of this species for any purpose is strictly prohibited. We have also seen video footage of mud and musk turtles on sale in Californian food markets. Again, these species are absolutely not available from commercial farms and can only be obtained from the wild. That such species were encountered simultaneously with Red-eared sliders forms additional and very strong circumstantial evidence for a wild-caught origin for all. Further, the presence of Clemmys marmorata in food markets conclusively demonstrates that illegal local collecting is certainly taking place.

2. Environmental impacts

The Tortoise Trust strongly supports the conclusions reached in the report produced by the San Francisco Society for the Prevention of Cruelty to Animals. We believe that there is absolutely no doubt that animals from these markets are being released in substantial numbers, and that others escape by themselves into the local environment. We ourselves observed live turtles being sold to persons who told us they regularly purchased turtles and bullfrogs to "rescue" them from the obvious cruelty inflicted upon them in these markets, and that rescued turtles and amphibians were subsequently "released in a nice place". We see no reason to doubt that many individuals, observing the callous disregard for even basic humanitarian standards of maintenance and slaughter typical of these markets, would indeed be sorely tempted to take some initiative of their own in order to save at least some from the gross abuse they are suffering.

a) It should be noted that the EC Council of Ministers (the European Parliament) has, of December 1997, determined that the importation of Red-eared sliders and bullfrogs be entirely prohibited throughout Europe on the grounds that it has been conclusively demonstrated that these species pose a serious and lasting threat to endemic wildlife.

b) Spiny softshell turtles are rare in the retail pet trade, yet introduced specimens are relatively commonplace in California inland waters. it is impossible to reach any other conclusion but that these turtles originate with the food trade.

c) The bullfrog (Rana catesbiana) is a serious predator of Western Pond turtles (Clemmys marmorata), a species which is listed in California as vulnerable. The bullfrog is an aggressive and highly effective predator of other amphibians, small reptiles, small mammals and birds. We believe that to continue to permit the bulk import of bullfrogs into California places vulnerable and endangered endemic wildlife in grave danger.

d) A very high percentage of the turtles and bullfrogs examined were obviously sick and were displaying symptoms of parasitic and bacterial diseases. We have studied the submission to the Commission by B. Bonner, MS, DVM dated 3 February 1998 and concur strongly with the conclusions therein. We are in no doubt that the import of such large numbers of contaminated animals represent a significant public health and environmental hazard. We noted butcher's slabs running red with blood and fecal material. We observed living turtles quartered on these boards and passed directly to customers. Turtles are major carriers of Salmonella organisms. Turtles are also frequent carriers of Herpes and Mycoplasma organisms, and the risk of released animals conveying such pathogens to local aquatic wildlife must be taken seriously.

Conclusion

There is no evidence to support the contention that the bulk of turtles sold in food markets in California are bred in captivity. Quite the reverse. Our investigation failed to detect a single captive-bred specimen. Without exception, the animals we examined were undoubtedly wild caught. This substantially alters the balance of environmental impact of this trade.

We further believe that these imports do indeed constitute a serious threat to the local environment as a result of unlawful releases and escapes. Furthermore, these animals are a serious threat to the health of both retailers and consumers in the State of California.

A. C. Highfield
Director, International Director, Tortoise Trust
Member: IUCN Species Survival Commission Tortoise & Turtle Specialist Group
Author: Encyclopedia of Keeping & Breeding Tortoises & Freshwater Turtles