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breeding facilities, throughout the world, are small, family owned facilities. Logically, 

 they would have great difficulty in dealing with exhaustive paperwork required for 

 approval of their facilities. If they could become approved, it is unlikely that they could 

 assemble enough birds to make a shipment financially feasible. Separate approvals are 

 required for each species. Not only must they meet the requirements of WBCA, but they 

 must deal with shipping expenses, quarantine costs as imposed by USDA and must allow a 

 margin of profit for the US dealer. If a foreign dealer could coordinate shipments for a 

 number of approved breeders, and even assist them in the approval process, economically 

 viable trade could occur. Otherwise only the most rare and valuable birds will be traded 

 due to the high costs. This serves NO conservation benefit. If the act is to truly enhance 

 trade in captive bred birds this section should be removed. The Act specifically allows the 

 appropriate foreign governmental authority to certify a facility. This is appropriate and 

 should not require extensive regulation by USFWS. 



Legislative history states and I quote "it is the intent of the "bill" to encourage 

 captive breeding both in the United States and elsewhere. Concern has been expressed 

 that the small scale breeders may wish to ship birds to the United States via larger scale 

 breeders, but may be precluded fi-om doing so under this act. It is not the intent of the 

 (Congressional) Committee to prohibit such transfers, and the Committee believes that the 

 Secretary has sufficient discretion to allow them under this bill. It is also the intent of the 

 Committee that the paperwork burden required of participating captive breeding facilities 

 be minimized, especially as it applies to small facilities that employ few people." 



My second area of concern is that of oppressive regulation by the USFWS under 

 the auspices of the WBCA. For example in Section 107: Qualifying FaciUties - the Act 

 has 6 requirements: 



I The facility has demonstrated the capability of producing captive-bred birds of the 

 species in numbers to be imported into the US fi'om that facility, 



2. The facility is operated in a manner that is not detrimental to the survival of the species 

 in the wild. 



3. The facility is operated in a humane manner. 



4. The appropriate governmental authority of the country in which the facility is located 

 has certified in writing and the Secretary is satisfied, that the faciUty has the capability of 

 breeding the species in captivity. 



5. The country in which the facility is located is a Party to the Convention. 



6. All the birds exported fi'om the facility are bred at the faciUty. 



The proposed regulations however required the breeder to make 33 statements, including 

 but certainly not limited to: A summary of legislation implementing CITES in the country. 



