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Samenwerkende Aquarium- en Terrarium Organisaties

SATO

* Achieve structural improvement of exotic companionship animal (pet) husbandry standards and relevant policy instruments.

Lobbying Activity

Response to Updating the list of invasive species threatening biodiversity and ecosystem services across the EU

14 Dec 2021

Dear Committee, The Samenwerkende Aquarium en Terrarium Organisaties (SATO) commented on the EU Invasive Alien Species Regulation's public consultations in the past and is grateful to provide her feedback once again. In our previous episode we voiced strong concerns over the interpretation of scientific facts and figures on the Pterois miles, pointing out skewed interpretations and dogma across several levels. Now we will continue our series with a similar approach, whilst also introducing new characters and a plot twist. Since choosing between; a) 'provide input on species #422\K', or b) 'ignore the topic' drives a perpetual lock-in it seemed more sensible to create a third option. Context: The Invasive Alien Species Regulation is evolving into an ideological debate where the line between Policy and Politics is increasingly blurred. As several of our fellow stakeholders point out, the Invasive Alien Species programme is weakened by it's poor recognition of species' biological characteristics, ecological differences and habitat suitability across distinct EU climate regions. We notice how dominant assertions pose a risk-averse policy as the only way forward, and stakeholders must adhere to decisions from EU officials since there is no alternative (TINA). However, many stakeholders keep forwarding exactly those alternatives as they experience a compelling urge to live up to their civic duties as EU-citizens. (Noticeable by, but not restricted to, https://europa.eu/citizens-initiative/_en) Among both commercial and non-commercial wildlife specialists there exists a strong recognition that our efforts must not be grounded in purely economic motives. Intervening on those policies which harm international trade may be legitimated for distinct cases, but we must focus on finding out which policy structures are successful and which are not. By adhering to knowledge democracy guidelines (https://www.researchgate.net/publication/274239011_Knowledge_Democracy) we continuously seek to find our niche within this policy development process. Realizing that international policy development is never easy, we propose solutions that capture the most salient points of debate whilst providing room for dialogue. As a non-commercial entity run by volunteers the SATO can only present its first draft of such a potential initiative. We recognize the adoption of a regionalized IAS framework as a widely acceptable course of action for the Invasive Alien Species Regulation. This method will be better attuned to internalize species' characteristics and lift trade barriers currently experienced by EU member states. In climate regions where non-indigenous species cannot survive or reproduce, a trade ban further estranges us city-dwellers from the beauty of wildlife. - After all, the keeping of indigenous animal species carries its own set of risk and must be adopted with caution. - To facilitate mutual learning and deep democracy decision making procedures in the regionalized IAS framework the SATO request the EU Commission to organize an annual multi-stakeholder congress on the EU Invasive Alien Species Regulation. During a series of public events and workshops input and solutions can be sought, with transparency and integrity at the core of possibly value-laden topics. This method can provide a wealth of information on stakeholder inclusion for policy domains where such processes are still in their infancy. Above all, it will recognize the efforts of stakeholders in providing expert input whilst stimulating a cooperative working environment for those involved. On behalf of Samenwerkende Aquarium en Terrarium Organisaties (SATO), Sander Bauer, Secretary
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Response to Preventing illegal trade in wildlife

28 Oct 2021

Dear Committee, Given the reasons outlined in your summary of the current Roadmap (Ref. Ares(2021)6044041 - 05/10/2021) it is not surprising that Wildlife Trafficking still occurs so vividly. Illicit traders seem either driven by a financial incentive or may truly believe their actions support the survival of wildlife by commodifying natural resources from fragmented habitats. On the consumer side, some exotic companionship animal keepers continue to purchase animals from disreputable sources, which obviously causes more harm to the very nature they seek to reconnect with (Uhm & Spapens, 2018, p. 240). Amphibian species are at the top of the current extinction ladder, closely followed by birds and reptiles. At present, the CITES regulations do not provide a cure-all for the illegal trade in Wildlife or Non Timber Forest Products. Additionally, the international governance sector fails to address a number of structural deficiencies, thus maintaining a possibly substantial number of reptiles and amphibians being smuggled across EU borders. To promote effective policy efforts and enhanced cooperation, the SATO must first highlight a skewed representation of the wildlife trade and explain how this adversely affects the legal trade among exotic companionship animal keepers and important fact-checked contributions to international wildlife policy. Following our arguments outlined below, the renewed Roadmap for the Wildife Action Plan is at a decisive moment of steering towards irreversible mistakes. We advise the Commission to read our report with care and consult with the SATO team for any further information. - Full input provided in the enclosed PDF -
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