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having very little problem obtaining proper documents. During 

 all my conversations with dealers and their customers, The 

 concept of requiring documentation to prove legitimacy was easily 

 understood and accepted. 



Checking questionable documentation in New Jersey is easier 

 because we have access to the records of in-state dealers. We 

 can also rely on the assistance of fish and game agencies in 

 other states should we wish to check the authenticity of a 

 questionable source. 



Checking the documentation from other countries is obviously 

 going to be more difficult. The WBCA allows the importation of 

 captive bred birds. The regulations necessary to scrutinize 

 this documentation has yet to be promulgated but they are already 

 under fire. 



I believe it is legitimate to require that a foreign captive 

 breeder document that his facility can actually breed the species 

 and numbers of birds they intend to export. I also believe we 

 should wait for the regulations concerning qualifying facilities 

 as defined in section 106 to be published before we complain that 

 they will be overly burdensome. 



The second issue involves the possibility that section 115 of the 

 WBCA will be implemented. Section 115 allows the Secretary to 

 promulgate regulations requiring marking (banding or tagging) and 

 record keeping. The USFWS has already stated in public meetings 

 that they do not intend to exercise this option since foreign 

 banding is not a sure way to distinguish wild-caught from captive 

 reared birds. I agree. Closed bands can be slipped on a young 

 bird taken from a tree by some black marketer in order to launder 

 it as captive bred. 



I should point out, however, that New Jersey requires that all 

 birds bred in-state be fitted with a closed band. Unbanded pre- 

 act birds must be banded with butt-end bands if resold. We 

 specify bands from a particular manufacturer but also recognize 

 bands being utilized already by members of the American 

 Federation of Aviculture, the National Finch and Soft Bill 

 Society and the Society of Parrot Breeders and Exhibitors. We 

 are also willing to allow bands from any other organization which 

 is willing to help us trace a bird if it becomes necessary. We 

 also allow micro-chip implants as an option for those wishing not 

 to band their birds. 



Although New Jersey law is stricter in this regard, there are 

 two points I would like to make. The first is that 

 banding/tagging always helps the legitimate constituent and is an 

 aid, although not fool proof, in apprehending the illegal 

 purveyor of birds. Secondly, several national organizations 

 have already recognized the value of banding as a method of 

 individually tracking birds for breeding purposes. For these 

 organizations, the banding is not overly burdensome but rather an 

 aid to good animal husbandry. 



