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The Wild Bird Conservation Act (WBCA), is based on limited and distorted information, as a 

 result inaccurate opinions and poorly understood assumptions were used to justify 

 outrageous regulations which, in the long run will be contradictory to the aim and goals of wild 

 bird conservation. The way in which the regulations are being written and promulgated by 

 the Fish and Wildlife Service, we will see the rapid extinction of many Central and South 

 American birds because of the onerous provisions of the WBCA and the bureaucratic 

 quagmire that they create. 



The WBCA stifles the activities of aviculturists who help protect wild bird populations in two 

 ways: 1 . captive breeding of birds for the pet trade takes much of the economic incentive 

 out of smuggling birds into the United States and 2. private aviculturists who are active in 

 conservation breeding programs, which will provide a valuable resource for future 

 reintroduction efforts. 



The World Wildlife Fund (WWF) publication. International Wildlife Trade , a CITES Source 

 book, recognizes the importance of captive-bred species as ". . . they enter trade legally and 

 are usually healthier and tamer than their wild caught counterparts." The book goes on to 

 detail that presently the only two parrots not regulated by CITES are commonly bred (by 

 private aviculturists) and they cite four more species are being bred in significant numbers 

 that will deter smuggling ( in my opinion there are dozens of species of birds being 

 domestically bred that deter smuggling). 



In his book, Last Animals at the Zoo , that deals with strategies for stopping mass extinction, 

 Mr. Colin Tudge, details the importance of the role of private aviculturists in conservation 

 breeding programs, in addition he laments the bureaucratic nightmare that sometimes 

 accompanies the efforts of conservation breeding programs, even before the present. WBCA 

 Regulations! The WBCA regulations are unreasonably complex and do not contribute to the 

 conservation of wild birds. 



In closing I wish to quote from Mr. Bruce Alberts, president of the National Academy of 

 Sciences, "Given time, political will and the intelligent use of science, human ingenuity can 

 find substitutes for wasteful practices, improve the human condition and the preserve the 

 earth's natural resources." The subcommittee on Fisheries, Wildlife and Oceans has an 

 opportunity to display the political will, recognize the need for intellegent science, and use the 

 ingenuity of private aviculturists to help presen/e wild bird populations by removing the 

 wasteful bureacracy of the WBCA regulations. Recognize the valuable contribution private 

 aviculturists have made to the preservation of wild birds and revise the regulations to 

 incorporate the recommendations provided by the position of the American Federation of 

 Aviculture. 



Sincerely 

 Martin Muschinske 



