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My final concern is regarding USFWS handling of permits. I have not personally 

 applied for any permits under WBCA, however over the years I have on many occasions 

 applied for permits fi-om USFWS for a variety of purposes, mostly for export of captive 

 bred birds. I have personally found the Service to be difficult, frequently taking excessive 

 time in permit processing. On permit applications requiring a foreign import permit which 

 is valid for 6 months, the foreign permit frequently expires before a decision is rendered by 

 the Service. The Service "appears" to be distrustful of its foreign counterparts despite the 

 fact that they are Parties to the Convention and duly authorized. I am VERY concerned 

 that this type of handling of other permits will carry over into handling of WBCA permits. 

 I can provide examples upon request. With the complexity of the permitting process, 

 timely handling of WBCA applications seems to be even more difficult. 



In closing 1 would like to reiterate that the Association of Avian Veterinarians and 

 I personally, endorse the purpose and spirit of the Wild Bird Conservation Act. We are 

 committed to the conservation of birds in the wild and to the establishment of species in 

 captivity. We are concerned however about some aspects of the WBCA as outlined above 

 and request consideration of amendment. We are also very concerned by the complex and 

 restrictive regulations of the USFWS, the tardiness of promulgation of regulations for 

 some vitally important sections of the act and their general demeanor in dealing with the 

 public regarding permits. 



The subcommittee report should include language which will convey to the 

 USFWS the intent to limit excessive paperwork, to hmit regulation to only that which is 

 necessary and to utilize the expertise of foreign CITES authorities in certification of 

 foreign captive breeding facilities. 



Mr. Chairman, thank you for inviting me here today. I am happy to answer any 

 questions you may have now or later. 



