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Our principal concern is that the Fish and Wildlife Service has 

 been slow to issue regulations on two other important provisions of 

 the Act, and those are the provisions that would allow imports of 

 birds from foreign captive breeding facilities and that would allow 

 imports of birds sustainably harvested from the wild. The details 

 of those two issues are best sorted out by the Fish and Wildlife 

 Service as the agency expert in these issues and charged with sort- 

 ing them out, but let me just highlight our basic concerns. 



Principally we are concerned because both of these provisions are 

 important to the conservation of birds in the wild. Allowing the im- 

 port of birds from legitimate captive breeding operations overseas 

 helps to reduce market pressures on wild populations. In short, by 

 helping to meet the demand for pet birds, imports from captive 

 breeding facilities help reduce the demand for smuggled birds, and 

 that is in everybod^s interests. 



Similarly, allowing imports of birds that are sustainably har- 

 vested from wild populations also can be part of a long-term con- 

 servation strategy for these wild populations. In projects all over 

 the world, WWF has found that when wildlife resources bring 

 value to local communities, the prospects for conservation are 

 brighter — people have an incentive to protect the birds and they 

 have an incentive to protect the habitat upon which the birds de- 

 pend. 



Both of these exemptions also pose obvious challenges. We need 

 to make sure that in allowing imports from foreign captive breed- 

 ing facilities we are not establishing fronts for the laundering of 

 wild birds. Secondly and more difficult, in allowing the harvest of 

 birds from wild populations we need to be sure that those harvests 

 are in fact sustainable. As I am sure Dr. Beissinger will talk about 

 in more detail, that is no mean feat. 



Our request is simple, and it is that the Fish and Wildlife Serv- 

 ice move promptly to issue the final regulations. Those regulations 

 need to recognize the hazards of allowing imports under these ex- 

 emptions and establish requirements sufficiently rigorous to assure 

 that we don't inadvertently open up trade that would be detrimen- 

 tal to wild populations. At the same time, the regulations should 

 recognize that imports under both of these exemptions can play an 

 important role in the conservation of wild populations and the reg- 

 ulations should not raise unnecessary barriers to imports under 

 those provisions. 



A related part of the Act that has also not received much atten- 

 tion is the mandate to the Fish and Wildlife Service to find ways 

 to help countries develop and implement better programs to man- 

 age their wild bird populations to assure that those populations are 

 protected and that any trade is sustainable. In my written testi- 

 mony I have suggested that this can be done under an existing 

 partnership between the Fish and Wildlife Service and USAID. 



In summary, this Act is already making a big difference. It does 

 not need any significant changes. Fish and Wildlife Service does 

 need to move forward with implementation, issuing final regula- 

 tions, finding a way to help range states improve their manage- 

 ment of wild populations and trying to make sure that it gets the 

 funds it needs to do that job. Mr. Chairman, we think the Act is 



