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facility". However, weakening Section 107, as was suggested, will open venues 

 for illegal 'laundering' of wild-caught birds through loosely defined captive 

 breeding facilities in foreign countries. Further, the Act will be 

 ineffective in protecting birds from inhumane treatment if strict regulations 

 are not placed on husbandry practices. The U.S. Fish and Wildlife Service 

 (USFWS) is in the process of establishing criteria for approving foreign 

 breeding facilities. This section should not be weakened before it is even 

 promulgated. 



The testimony sutanitted by the American Federation of Aviculture (AFA) 

 expressed their impatience with the WBCA in providing immediate results from 

 sustainable-use population studies. Their view appears to be that if such 

 studies are not con^leted in a timely manner, then iir^ortation should resume 

 in an 'ignorance is bliss' manner. 



At the same time that AFA representatives testified at the Congressional 

 Hearings that the U.S. government should be funding biological studies in the 

 field, Mr. Rick Jordan (First Vice-President, AFA) outrageously criticized 

 studies of parrot species in the field. Mr. Jordan referred to the WBCA as 

 "stupid" in an article published in the AFA magazine (AFA Watchbird. 12(5) :45- 

 47. 1995; enclosed). In my opinion this article galvanizes readers against 

 the WBCA in its current form. How can he claim he supports the WBCA and 

 conservation when he appears so cynical about scientific studies of birds in 

 the wild? 



The Pet Industry Joint Advisory Council (PIJAC) is concerned that the 

 WBCA is too restrictive and is therefore destroying the import industry. They 

 claimed that there has been a decrease in the numbers of active importers from 

 "30-40 to 6-7". The WBCA was designed for the protection of birds, not the 

 economic interests of a few. If the U.S. appeared as a large vacuum cleaner, 

 the importers appeared to represent the nozzle. 



Another issue presented by the AAV representative concerns the 

 inconvenience of the permit application process. The permit application 

 process was not designed to be convenient, it was made to be thorough. It 

 takes time to verify the legitimacy of any request for import of species 

 covered by Convention on International Trade in Endangered Species (CITES) and 

 the WBCA. My research in genetics requires feather seimples from several CITES 

 bird species. The feathers are collected in a non-destructive manner, yet 

 require import permits from the U.S. and export permits from the country of 

 origin. My permit applications are lengthy requiring as long as three months 

 to process. The aviculturists are not being singled out for harassment. The 

 USFWS conducts necessary investigations for each request for importation of 

 birds or bird products. The permit application process is as lengthy as it 

 needs to be to ensure the protection of the birds. 



In my opinion the testimonies presented by the AFA, AAV and PIJAC are 

 focused on eliminating any regulations within the WBCA that restrict 

 convenient in^ortation of exotic birds. Yet these regulations are precisely 

 what guard against inhumane treatment and over exploitation of birds in 

 foreign countries. I do not interpret their testimonies as support for bird 

 conservation in their native habitats. Their definition of conservation 

 appears to be breeding rare species in captivity so as to preserve them there 

 for eternity in an artificial environment. In my opinion the most important 

 role that aviculturists can play in conservation is to breed domestically 

 those species that are in demand by the pet industry, thereby reducing demand 

 on wild birds. Aviculturists may also play a role working closely with 



