I called the PACFA office, and the admin assistant was actually very nice. I was told, however, that it does not matter how many animals one has, or how much money you do or do not make from them. If it is for the "pet trade", it is not considered "unregulated wildlife". They want to license your "facility", license the right to sell at shows, and license the right to sell wholesale. They want a separate license if you breed mice or rats, and told me I needed a federal USDA license to ship across state lines. They claimed to be going to pet stores to insure that they are purchasing animals only from licensed breeders, will be attending shows to make sure all vendors are licensed, and are researching websites and online forums, looking for Coloradans actively trying to sell reptiles. They want everyone licensed, "for the good of the animals". On the brighter side, she asked if I could specifically define the difference between the hobbyist and the person just in it for the money. I could not, and she admitted that they could not either. She actually asked for feedback from me and other hobbyists, and suggested that with enough input, they could modify the regulations in order to keep tabs on the businesses without hampering the basement breeders. I told her that hobbyists were not likely to contact them because they did not want to be on a list of future inspections. I said that the hobbyists needed an advocate to speak for them, and USARK came to mind. She was actually rather excited by that idea, and said that they would welcome a dialog with the hobbyists.
I see this simply as a power grab by the Dept of Ag, and an opportunity for them to make a ton of money for doing next to nothing. Fully implemented, PACFA could squash the reptile industry in Colorado, without helping a single animal. We do indeed need an advocate.