Ill 



3, Assisting wild bird conservation and management programs in foreign 

 countries. 



4. Encouraging and promoting captive breeding. 



Three years after enactment, the pet industry, aviculture, and others supportive of 

 sustainable use programs anxiously await implementation of key portions of the WBCA 

 that would facilitate importation of captive-bred birds and wild-caught birds harvested 

 pursuant to U.S. -approved foreign conservation management programs While it may 

 have been the intent of Congress that the WBCA would accomplish these laudable goals, 

 it appears that the Service's actions reflect a far different intent. The proposed regulations 

 governing approval of foreign captive breeding facilities and foreign sustainable-use 

 conservation export programs are so restrictive and burdensome as to promote 

 disincentives, not incentives, for engaging in any of the activities contemplated by the 

 Congress. 



No foreign captive breeder, no foreign government, and no U.S. importer will 

 make any substantial investments in light of the high probability of denial by FWS as well 

 as the risk of running afoul of aggressive FWS anti-wildlife-use law enforcement in the 

 FWS. The risk is simply too great. 



The impact of the WBCA on the commercial pet bird industry has been and 

 continues to be significant.' It has destroyed the import industry and adversely affected 

 the supply of birds, both captive bred and wild-caught. Prior to enactment, the avian 

 import program consisted of approximately 30 to 40 active importers responsible for 

 importing slightly more than 320,000 birds for pets, captive breeding, zoological display, 

 and re-export. For FY 95, USDA reports that only 55,166 birds have been received in 

 U.S. quarantine facilities. Following enactment of the WBCA, only 6 to 7 active 

 importers remain. Part of this attrition is directly related to economic conditions, shifting 

 consumer preferences, increased domestic breeding of the larger Pssitacine species, not the 

 WBCA As the import industry is fiirther decimated, importation will become more than 

 simply "difficult" for cooperative breeding programs, captive-bred birds, and the few wild- 

 caught birds allowed access to U.S. markets. 



. What has the WBCA actually accomplished? 



1. An inability of foreign captive breeders to obtain U.S. 

 approval of their breeding facilities; 



2. An inability of foreign governments to gain U.S. approval of their avian 

 sustainable use conservation programs; 



3. A failure to attain funding necessary to implement the act; 



4. A failure to provide foreign assistance to those countries seeking to 

 implement U.S. approved conservation programs, and 



The commercial industry sales of live birds and related products (i.e., feed, cages, toys, 

 medications) approximates $SSO million dollars annually. 



