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Mollie Beattie 

 Page Two 

 April 25, 1995 



Since the implementation of the WBCA, The Peregrine Fund has been attempting to 

 import a non-releasable Harpy Eagle as part of an on-going species restoration program and has 

 found that this new addition to the permit process has made an already unworkably ponderous 

 and redundant system even worse. 



I provide our experience with this import request as an example of what this new 

 legislation has required of both Service and The Peregrine Fund staff. In January of 1994 we 

 encountered a non-releasable aq)tive Harpy Eagle in Venezuela during the course of our on- 

 going field research on this species in that country. Both the government of Venezuela and The 

 Peregrine Fund decided that the best use of this individual would be as part of the captive 

 breeding program at our facility in Idaho. The Peregrine Fund submitted an ^plication for a 

 CITES import permit to the Office of Management Authority on Fd)ruary 8, 1994. We were 

 notified that under the newly adopted WBCA, we would be required to form a 'Cooperative 

 Breeding Consortium" prior to being able to submit a request for a CITES import permit. 

 Following the instructions of the Office of Management Authority, The Peregrine Fund 

 submitted applications for a Cooperative Breeding Program under the WBCA. This request was 

 approved (PRT-CB003) on September 6, 1994, two days short of seven months. At this point 

 we were able to re-activate our request for a CITES import permit which was issued (PRT- 

 787554) on January 17, 1995, fully eleven months and nine days from the date when application 

 was submitted. I would also add that this is the seventh such permit request submitted by the 

 same applicant, for the same species, and for the same conservation program. 



Clearly the intent of the WBCA was to control the large scale importation of wild birds 

 into the United States, principally psittacines, that were destined for the pet trade. When this 

 act was first circulated for public comment we were generally in agreement with its stated intent, 

 that being the control of wild birds being imported for the pet trade. However, upon 

 implementation the WBCA has gone far beyond its original stated intent of controlling the 

 importation of wild birds for the pet trade, but now includes aU wild birds imported for any 

 reason, including legitimate conservation. 



On two different occasions, prior to the implementation of the WBCA, The Peregrine 

 Fund has provided written comment (copy enclosed) to the USFWS recommending that all 

 Falconi formes be excluded form the provisions of the WBCA on the rational that (1) raptors 

 have never been included in any pet trade, (2) raptors are already subject to the strictest control 

 of any bird group in this country and can only be possessed under stringent federal and state 

 permit, (3) raptors are already adequately protected under CITES, ESA, and MBTA. (4) the 

 WBCA represents an additional permitting hurdle for both applicants and service personnel, 

 seriously interfering with our ability as a nation to contribute to raptor conservation on an 

 international level. 



Mollie Beattie 



