In the near future the U.S. Fish and Wildlife Service will initiate a review of the listed species under the current U.S. Endangered Species Act (USESA). Following this review, additions of species of birds may be proposed for listing under the USESA. Changes in listing could have an impact on the keeping, breeding and transportation of exotic bird species in the U.S.
In order to prepare for this review, last year the A.FA. CITES. Committee designed a short breeder survey to try and determine something about the number of CITES Appendix I listed species that were being kept and bred in the avicultural community in the U.S. This data is of importance because it will provide information that will assist in making determinations about the listing of species. When species are known to be bred in captivity in certain numbers, and this number constitutes a "self-sustaining captive population,'' that data may preclude the listing of those birds under the USESA.
Some commonly kept and bred parrot species are already listed under the USESA. This listing requires the breeders to obtain Captive-bred Wildlife (CBW) permits for sales or barter that takes place across a state line. This means that many transactions with these listed birds across a state line requires a permit. Penalties for violation of this statute are stiff Furthermore, the USESA specifically prohibits the issuance of this permit for "pet trade" purposes. The sale or trade of these listed birds within a state does not require the CBW permit. These regulatory requirements have a profound effect on several avicultural aspects on the listed species: the gene pools, bird breeders' interest in breeding the birds, and the breeder's ability to sell, trade or place the listed birds.
Therefore, it is the contention of many leading aviculturists that this CBW requirement actually discourages aviculturists from breeding the listed species. First, when restrictions are placed on the sale, trade or transportation of a specific species, that automatically places severe
limits on the placement of youngsters produced because it shrinks the pool of potential buyers or owners. Many serious bird breeders are basically hobby breeders; they do not earn their living raising birds. They raise birds for the enjoyment of the species and their interest in conserving the species. Thus, these individuals do not want to be bothered with applying for government permits and waiting for weeks to pass before they can complete their transactions. The CBW permit regulation regarding selling or transacting across state lines is a definite deterrent to the breeding of listed species.
Additionally, the requirement that the USESA listed species will not be issued a permit for a sale that is essentially a "pet trade" purpose. This is an unreasonable requirement because it does not address the fact that a specific pair of birds may 'over-produce' in terms of the need for their offspring for maintaining a viable gene pool of these birds in the US. When a specific pair is highly productive, it makes sense to hold back two or four offspring for the gene pool and to distribute the rest of their offspring into the pet trade. This achieves two goals: 1) it provides income for the aviculturist to be able to continue to work with the producing pair, rather than stop their production and simply hold them in the facility; and 2) it sends the extra youngsters out to the general public where they become ambassadors for the species. As the general public becomes acquainted with a species, their interest is aroused and can translate into conservation efforts on behalf of that species.
Another problem that is caused by the CBW permit requirement is the resulting inbreeding of these rare species by breeders and holders that refuse to participate in the CBW registration system. Because these individuals do not want to deal with the permit process, they will only sell to other breeders within their own state. Eventually, most of the birds of that species within that state become related,
thus reducing the viability of the overall gene pool for that species within the United States. When there is no permit requirement, most breeders are willing to ship birds throughout the U.S.
Thus, it is our contention that the USESA CBW permit requirement results in three serious problems for aviculturists: 1) the creation of inbreed gene pools within states, 2) a reduced interest in breeding USESA listed species, thus reducing the long term preservation of the species in captivity, and 3) the potential for making felons out of honest parrot breeders due to lack of information or expertise in following USESA requirements.
We have serious concerns about the efforts of certain high-profile powerful organizations that will provide input to the review process. These efforts may result in more commonly kept and bred parrot species being added to the list of birds that would be required to have a CBW permit or an Interstate commerce permit for sales across state lines. During the review process, the AFA may send out information about the review so that individual breeders can provide their comments to USFWS.
Surveys such as this one are extremely important to the future welfare of aviculture in the U.S. Virtually all law-making bodies now rely on this type of census data during their decision-making concerning legislation and regulation. Without sound statistics, laws are often made using mere assumptions or estimates. These estimates and assumptions may be happily provided by groups that oppose aviculture in principle and the keeping of birds for any reason. Unless and until the members of the avicultural community recognize this situation fully and contribute data to these types of surveys, we will be at a distinct disadvantage in the legislative arena.
Although it may appear that this survey was a success, please note that ONLY 3 % of all AFA members even bothered to respond. There are some very large breeding facilities in Florida, Texas and California whose data is obviously missing from this survey. The AFA CITES Committee offered all respondents anonymity in answering the survey.