25 



21.30. He has to seek an MBTA import or export permit, and he 

 has to comply with the additional requirements imposed by CITES. 

 And then for those few birds, not only the peregrine falcon, for any 

 import or export then he has to also seek an additional ESA per- 

 mit. 



When the ranking minority member had said it was a first-time 

 regulated group of people and they are getting used to the Act, we 

 have been used to it for a long time. If Mr. Striegler of law enforce- 

 ment were sitting here, he would recall a meeting that I had with 

 Mr. Doggett, Chief of Law Enforcement with the Fish and Wildlife 

 Service, who said isn't there any way that we can decrease the 

 number of regulations dealing with raptors. And frankly, we have 

 resisted. We have a marking system. We have a requirement of ap- 

 prenticeship. We have very stringent requirements for facilities and 

 examinations. The same things go for people who would seek to 

 captively breed raptors in captive propagation programs as well. 



So we come to point out to this committee that despite all of 

 those purposes, there is one purpose that we are not allowed to 

 keep raptors for, which is the basic intent of this Act; and, that is 

 for pet purposes. You cannot keep a raptor in America for pet pur- 

 poses, so the basic intent of the Act really doesn't adequately cover 

 any problems with raptors that might not be covered with all of the 

 other acts. Consequently, notwithstanding the recommendation of 

 the gentleman from Yale, we really believe that the Falconiformes 

 family ought to be exempted from the Act so that the WBCA more 

 appropriately can be focused on the real problems that you dis- 

 cussed with the previous panels and more broadly with the remain- 

 der of this panel. 



What WBCA means is that for people who are dealing with 

 raptors, it means just one more permit. That is, we are up to five 

 permits instead of just four now without the WBCA. I will tell you, 

 though, that with respect to the fact that we have had to deal with 

 it for the past couple of years until this reauthorization hearing, of 

 the captive propagation programs which have been approved, prob- 

 ably the majority have been for captive propagation programs deal- 

 ing with raptors. And that is frankly because the Service has dealt 

 with us for a long time, knows who we are and knows the stand- 

 ards that we have to live with. So I am sure it has been a lot easier 

 for the Service to deal with us than it has for some of the other 

 bird groups. 



But it brings us to a broader problem, particularly with the Serv- 

 ice and the permitting activities. We routinely have permit re- 

 quests that go six to nine months without a decision. We are very — 

 feel very lucky any time it is under 120 days, and what — ^when peo- 

 ple talk about the system and feel that it maybe doesn't need much 

 more than a little tweaking, a little work here and there, I find 

 that the permit system is not broken. It doesn't need a little tweak- 

 ing. The permit system at the Fish and Wildlife Service is in com- 

 plete meltdown. It needs to be rebuilt, and I think this committee 

 and other committees in Congress that deal with it really need to 

 deal with that part of assisting the Service to integrate a program 

 so that we have single permitting system for the various purposes 

 and to assist them in their capacity to issue permits timely within 

 the standards that they are being guided by. And I do hope that 



