160 



^ The Peregrine Fund 



WORLD CENTER FOR BIRDS OF PREY 



Focusing on birds of prey Jot conservation of nature 



^ 



May 12, 1994 



Director, U. S. Fish and Wildlife Service 

 1849 C Street NW 

 42 ARLSQ 

 Washington, DC 20240 



Re: Comment, Proposed Rule; Importation of Exotic 



Wild Birds to the United States; Proposed Rule 

 Implementing the WBCA of 1992; Federal Resistor, Vol. 59, 

 pp. 12784 et seq., March 17, 1994 



Dear Madam: 



Thank you for the opportunity to comment on the above 

 referenced proposed regulations. Our recommendation is sir.ple - 

 exclude all Falconif ormes from the provisions of the Wild Bird 

 Protection Act (WBCA) . 



As an organization we base the recommendation on almost 25 

 years of experience nationally and internationally, primarily in 

 research and conservation of birds of prey and their habitats. We 

 have cooperated on projects in over 4 countries on six continents. 

 Personally our combined experience with raptor research and 

 conservation internationally exceeds sixty years. 



Import of raptors into the United States does not jeopardize 

 any species or population internationally. The WBCA provides no 

 benefit to Falconif ormes, in fact it does just the opposite by 

 causing those working to conserve raptors to waste their time 

 dealing with yet another set of regulations and application 

 procedures. CITES, the Migratory Bird Treaty Act, and the 

 Endangered Species Act already provide more than adequate 

 protection and regulation for Falconif or-es. 





