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Comments on the USFWS Bird Conservation Act
by Mark Hagen
Problem with setting criteria for the approval of certified breeding facilities, domestic or foreign.
A brief summary of the 1992 Bird Conservation Act has been issued by USFWS and is attached. The final rules for foreign breeders have not yet been published but the proposed rules have, and contain several requirements of concern.
The Act states that breeding stock should have been established in a manner that was not detrimental to the survival of the species in the wild. Problem: some species that were bought legally and in good faith by
breeders have turned out to have been unsustainably harvested, and were exported by countries of origin over the recommended and stated export quotas. The final owner, the aviculturist, should not be penalized because of a failure of the Tropical countries to regulate their trade.
Range vs Non Range countries differ in their potential for illegal trade. This has not been addressed in the foreign section, even though I pointed this out to Dr. Susan Lieberman in September 1993. There is no need for excessive regulations to be placed on Canadian or European breeders if there are no endemic wild exotic birds in these countries which could be laundered as captive bred.
Husbandry practices of a facility (which are requested) pose a major problem with the proposed rules. Criteria relating to husbandry have nothing to do with legality of the captive bred birds coming from a facility and are therefore a USDA issue. USFWS does not have the resources to enforce the Animal Welfare Act.
Feeding methods can vary greatly between successful operations. Differences between indoor and outdoor facilities, the background of the breeding stock and many other differences in species requirements make the husbandry practices of the facility unique, and questioning it in a fair system of rules is unmanageable. Disease rates can be periodically unrelated to the design of a facility and even a facility with a very generous budget for caging, veterinary care and labour can experience a viral problem for which a diagnostic test, vaccine or cure is unavailable. It is groups such as AFA, IAS and AAV that have contributed to developing techniques to reduce these diseases.
Disease rates in fact have been significantly reduced due to the availability and voluntary use, when appropriate, of CTC pellets, Pacheco's Herpes Vaccine, Beak & Feather virus diagnostic test, with more soon to be available.
In summary the husbandry practices of any facility are best decided between Aviculturists and their Avian Veterinarians and should not be under scrutiny by USFWS. All questions related to husbandry should fall back to the Model Aviculture Program which is also being used Internationally as well as in the USA. There should be no delays in an already lengthy process in issuing permits between countries if the CITES requirements are met. The decision to allow the export of Appendix II species rests solely with the
Canadian CITES office and should not be controlled by foreign offices. CITES was designed to allow for international trade in common species and second generation, captive bred endangered ones. Europe, and now the USA, are overriding CITES with their own complicated and restrictive domestic legislation. This is resulting in a barrier to trade, and questions the
motives of those writing the legislation. Dr. Susan Lieberman, the CITES Secretariat for USA, worked previously for HSUS. We have a Vegetarian in charge of the chicken coop. Go figure!
Often pet birds are moved between Canada and the USA. To help individuals with the permits required, the USFWS has issued the attached information sheets (including a CITES form) which need to be filled out.
NY State has controlled parrot breeders for 9 years. Attached is the law and an update. The importance of MAP in self regulation cannot be over emphasized.