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production levels for the last few years and future anticipated production, a breeding 

 protocol, genetic management plan, details of breeding techniques, number and origin of 

 original stock, statement that the parental stock was established without detriment to the 

 survival of the species and certification that original stock was legally acquired, statement 

 of anticipated augmentation, descriptions or photos of facilities, husbandry practices, 

 veterinary care, records of disease and mortality, qualifications of care takers, record 

 keeping systems, trade data and a statement that enforcement controls are in place in the 

 country to prevent laundering. The secretary must then use 13 points in evaluation of 

 applications. A separate application must be made for each bird. Approval is valid for 2 

 years. 



These regulations have been published ONLY as proposed rules, 3 years post 

 enactment! It is my understanding that the USFWS received in excess of 5000 letters 

 protesting the proposed rules for this section of the Act. 



In recent discussions with Mark Phillips of the USFWS, he stated that as of late 

 August 1995, 673 WBCA permit applications have been received and 562 of these have 

 been approved. However, 620 or 92% of these applications were for pet birds of US 

 citizens returning to the US. 



Final rules implementing other exemptions under the WBCA have been published, 

 and they are significantly better that the proposed rules. Compliance with the proposed 

 regulations for imports under exemptions for Scientific research. Zoological display and 

 Cooperative Breeding programs and imports was virtually impossible especially for the 

 average citizen. The Final rule was published on November 16, 1993 and many of the 

 almost impossible restrictions were removed, however the final rules is still so oppressive 

 that only 53 total permit applications ( 7 for scientific research, 27 for zoos, and 19 for 

 cooperative breeding programs and imports) have been received by the service of which 

 only 34 (64%) have been approved. It is my behef that the regulations are so complex 

 that apphcants are intimidated, afraid to attempt application. These regulations must be 

 simplified in order to make the act work. Oppressive regulation has NO conservation 

 benefit. The purpose of the act was to limit the massive, unsustainable trade in wild 

 caught birds for pets, not to make imports under the exemptions so difficult. 



Sustainable utilization of resources has been widely endorsed by lUCN and other 

 global conservation authorities as the primary means of conservation of those resources. 

 In an age when the worlds human population continues to squeeze wild areas, adding 

 value for the protection of habitat must be paramount. Sustainable utilization of exotic 

 birds is the only logical way that this Act will benefit wild populations. Granted the 

 reduction of imports into the United States has reduced part of the demand on these 

 populations, however, the pressures are still there. Growing human populations, habitat 

 destruction, internal trade and trade to other regions of the world continue unabated. The 

 concept of the US funding conservation programs in other countries sounds good but is 

 illogical in times of fiscal restraints. Despite this, no proposed rules have been published 

 for implementation of this section of the Act - three years post enactment. 



