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implemented an adequate management plan for their conservation, or if they are bred in captivity. 

 An exemption to this rule is provided for four categories of non-commercial imports: zoological 

 display, scientific research, cooperative breeding programs, and personal pets. Birds that are not 

 listed under CITES can be imported unless the Fish and Wildlife Service (FWS) finds that they 

 are threatened by trade. 



Exemptions under the WBCA 



As noted above, the WBCA provides four exemptions for bird imports: for scientific 

 research, zoological breeding or display, and cooperative breeding programs; and pet owners 

 may bring their pet birds into the country after living abroad. WWF believes the regulations and 

 permit application requirements for importing birds pursuant to these exemptions are reasonable 

 and not overly burdensome. Experienced and qualified breeders should not have difficulty 

 providing the information that is required. It was anticipated that this exemption would be used 

 for the importation of wild caught birds, in which case the information is warranted and 

 appropriate. However, this exemption is also being used for the time being for the importation 

 of birds bred in captivity, since the regulations for the approval of foreign captive breeding 

 facilities have not yet been issued. We understand the frustration on the part of those who have 

 found that this was the only route available for the importation of a bird from a captive breeding 

 facility. The sohition is not to change the requirements for imports under the exemption, but 

 rather to expedite the regulations for the approval of foreign captive breeding facilities. 



Regulations for M3 nap ;ement Plans and Breeding Facilities 



The WBCA broadly defines what constitutes an adequate management plan and qualifying 

 foreign breeding facility, and delegates authority to the Fish and Wildlife Service to issue 

 regulations containing specific criteria, and to process applications submitted pursuant to those 

 criteria. Unfortunately, Congress has not provided sufficient funds for the FWS to implement the 

 WBCA, and the issuance of final regulations has been delayed for nearly two years. As a result, 

 many birds bred in captivity in foreign countries caimot be imported, and there is not yet a 

 procedure for importing birds from countries with sound management programs. 



The fact that final regulations are not yet in place is especially troubling with respect to 

 the import of birds from qualified captive breeding facilities in foreign countries. Because these 

 regulations have not been issued, the WBCA has unintentionally closed a viable source of captive 

 bred birds. That was clearly not intended: die Merchant Marine and Fisheries Committee Report 

 on the WBCA acknowledged that "successful breeding of species of birds popular in the pet trade 

 may help reduce the pressiu-es on wild populations by iiKreasing the numbers of birds that are 

 available from captive-bred sources in both the United States and elsewhere." We urge the Fish 

 and Wildlife Service to expedite the issuance of those regulations and, if it appears that additional 

 delay is unavoidable, to consider providing an interim means of importing birds listed on 

 Appendix II and m to CITES when they are verifiably bred in captivity. 



The proposed rules on foreign captive breeding facilities have generated heated 

 discussion. While it is important to use care and scrutiny in overseeing foreign breedmg facilities 

 to ensure that diey are not used to launder wild<aught birds, WWT believes that the regulations - 



