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unnecessary. Since passage of the act however, it is my feeling that the regulations 

 promulgated by the US Fish and Wildlife Service have been excessively restrictive and 

 represent an excessive and unnecessary paperwork burden for those who wish to import 

 birds under the exemptions provided by the act. Publication of some regulations has also 

 been delayed excessively, for example, the Final rule establishing the exemption for 

 sustainable utilization has not yet been published, almost 3 years after passage of the act. 



I have several specific areas of concern which I hope will be addressed by the 

 Subcommittee. 



First, I am concerned about several specific points in the bill which I feel should be 

 revised. Second I am concerned about the regulations as promulgated by the US Fish and 

 Wildlife Service which are complex, restrictive, and burdensome. Third, I continue to be 

 concerned about the handling of permits by the Service. 



I strongly feel that there are several sections of the WBCA which should be 

 revised. 



Section 115: Marking and Record Keeping 



The regulation, ie marking, of captive birds within the United States provides NO 

 conservation benefit for birds in the wild. I strongly believe that all birds, both pets and 

 avicultural stock, should be marked for health and animal management reasons. On April 

 10, 1994 numerous aviculturists demonstrated to the US Fish and Wildlife Service that 

 voluntary programs exist and function well. While closed banding is recommended by 

 many if not most aviculturists in the US, many veterinarians still routinely remove bands 

 for safety reasons. While I disagree, I must respect the opinions of my colleagues. 

 Currently, the electronic identification systems available in this country are not compatible 

 and are too expensive for widespread use. 



Any system of mandatory marking and reporting would be exorbitantly expensive 

 to implement and maintain. Unless a extraordinary public health or animal health reason 

 existed the expense of such of program could never be justified. For example, the control 

 of Rabies, a major public health concern, requires vaccination and licensing of all dogs and 

 cats. This program is intensively managed on a county basis throughout the US. Despite 

 costly implementation, compliance is generally 50% or less. This marking section of the 

 bill should be removed as it is a point of concern and anxiety for aviculturists, has no 

 conservation benefit and is virtually impossible to implement. It is not a deterent to 

 smuggling and provides no conservation benefit for wild populations. 



Regarding Section 107: Qualifying Facilities ( for export of captive bred birds to 

 the United States), (b) (6) "All birds exported fi-om the facility are bred at the facility." 



This requirement of the WBCA is very restrictive and virtually eliminates the 

 potential for economically viable trade in captive bred birds on a commercial basis. As in 

 any business enterprise, some volume is necessary for trade to be profitable. Most 



