Parrots International Position Statement on Proposed Addition of 14 Parrot Species to the US Endangered Species List

tags: US endangered species list, parrots, aviculture, captive breeding, position statement, Parrots International, politics

NOTE: This position statement just came to my attention. I wish I had learned about it on 10 August, since I would have shared it immediately on that day.

August 10, 2009

Public Comments Processing
Attn: FWS-R9-IA-2009-0016
Division of Policy and Directives Management
U.S. Fish and Wildlife Service
4401 N. Fairfax Drive
Suite 222; Arlington, VA 22203

As president of Parrots International I am forwarding the official position statement of Parrots International in opposition to the proposed addition of 14 species to the Endangered Species Act (FWS-R9-IA-2009-0016).

Parrots International is a non-profit organization dedicated to field research and conservation of endangered parrot species. We have extensive experience regarding in situ parrot conservation. We work in strategic international partnerships to promote parrot conservation in the wild. We presently have over 14 field research and parrot conservation projects in Central American, South America and the Caribbean. The USFWS awarded Parrots International the "Partnership in Conservation" award in 2006 for our support of the USFWS captive breeding and recovery efforts for the Puerto Rican Parrot, and, Parrots International is an official USFWS fundraiser and consultant for the USFWS Puerto Rican Parrot Recovery Project.

Parrots International is funding and involved in active conservation projects in the field (in situ) with the following species proposed for addition to the U.S. Endangered Species Act (ESA):

-- Blue-throated Macaw (Ara glaucogularis) -- Beni Department, Bolivia
-- Great Green Macaw (Ara ambiguus) -- Costa Rica
-- Hyacinth Macaw (Anodorhynchus hyacinthinus) -- Pantanal, Mato Grosso de Sul, Brazil
-- Military Macaw (Ara militaris) - Oaxaca State, Mexico
-- Scarlet Macaw (Ara macao) - Guatemala and Nicaragua

The Parrots International Position Statement
From the perspective of Parrots International, a parrot conservation organization, there is no arguable substantial scientific value to adding these 14 parrot species to the Endangered Species Act.

An examination of the potential value (conservation) of the addition of additional exotic species to ESA:

1. Will the addition of these species to the ESA decrease illegal trade? No.

   a. Listing under the U.S. ESA will not decrease illegal trade in these species. The Wild Bird Conservation Act and CITIES [sic] are the proper vehicles to decrease illegal trade. Of the 14 proposed species additions, ten are CITIES Appendix I listed, the highest protection afforded by CITIES, which presently requires both import and export permits for international trade and commerce. Furthermore, under current CITES resolutions, all commercial trade in these species is prohibited.

   Blue-throated Macaw (Ara glaucogularis)
   Blue-headed Macaw (Primolius couloni)
   Great Green Macaw (Ara ambiguus)
   Hyacinth Macaw (Anodorhynchus hyacinthinus)
   Military Macaw (Ara militaris)
   Philippine Cockatoo (Cacatua haematuropygia)
   Red-crowned Parrot (Amazona viridigenalis)
   Scarlet Macaw (Ara macao)
   Thick-billed Parrot (Rhynchopsitta pachyrhyncha)
   Yellow-crested Cockatoo (Cacatua sulphurea)

   The remaining four species are CITIES Appendix II (which only allows sustainable trade). But virtually all commercial trade in these CITES Appendix II species is still prohibited under our own Wild Bird Conservation act of 1992.

   However, the Wild Bird Conservation Act of 1992 (WBCA) prevents the importation in all 14 species into the US. Therefore, addition of these species to the U.S. ESA will provide no additional trade restrictions.

2. Will the ESA provide protection on lands under United States control? No.

   a. None of the 14 proposed species are endemic to lands controlled by the US. Nor is the US likely to control these foreign lands in the distant future.

3. Will the ESA provide funding for recovery of these 14 species? No.

   a. There are no appropriations or funding for exotic species listed under the U.S. ESA. Congress had failed, since 1972, to provide funding for this law to protect, enhance, or otherwise conserve exotic, listed, species.

An examination of the drawbacks (negative conservation) of the addition of these 14 species, or any exotic species, to the U.S. ESA:

Parrots species not presently listed on the ESA are represented by genetically healthy viable populations in US aviculture. The founder birds of these healthy US captive populations were imported prior to the WBCA in 1992. The WBCA act has successfully prevented importation of these species since 1992 (protected wild parrot species from trafficking).

Every parrot species currently listed under the ESA has suffered severe negative consequences in efforts to maintain a captive-bred genetically viable population within the US. In fact, due to the onerous placed on breeders to obtain Interstate commerce permits or Captive-bred wildlife registrations to sell birds across a State line, inbreeding coefficients of species currently listed are very high. Furthermore, the captive populations of many species listed on the ESA have decreased. Captive, responsibly bred, populations of these parrots may be very important in the future. The USFWS Puerto Rican Parrot captive breeding program is a case in point. Without captive breeding and supplementation of the tiny wild population, the Puerto Rican Parrot would most certainly be extinct today. The proposed legislation would unilaterally negatively affect captive breeding efforts of these species with no foreseeable positive consequence on the wild populations:

1. Adverse effect on captive-bred populations of past ESA listed (exotics) parrots:
   1. The Golden Conure (Guaruba guarouba) example:
      Listing of the Golden Conure has had a severe detrimental effect on its captive breeding. Listing on the ESA places severe restrictions on the sale and movement of this species within the US and between states. This legislation, which was in fact intended to conserve the species, has resulted in a detrimental decline in the captive population size and genetic viability.
   2. The Cuban Amazon (Amazona leucocephala) example:
      The Cuban Amazon has become one of the most poorly represented parrots in US captive breeding efforts.
   3. The Thick-billed Parrot (Rhynchopsitta pachyrhyncha):
      The Thick-billed Parrot is almost unknown in US aviculture and captive breeding efforts.

Regarding the Blue-headed Macaw. Recent wild population estimates of the Blue-headed Macaw by Brightsmith, et. al have demonstrated that the wild population is far larger and more widespread than previous estimates. Based on this recent data, Bird Life International is presently considering "downlisting" the species from its Red List, from "Endangered" to "Vulnerable".

In summary, there is no viable scientific value in adding these 14 species to the U.S. Endangered Species Act.

Conversely, there is a predictable detrimental consequence of this addition, whereby the captive breeding population and domestically supported genetic diversity of these species will be negatively affected.

Currently, captive breeders and aviculture in general, are the main potential contributors of reintroduction captive individuals to in situ conservation efforts of exotic parrot species. To further limit their commerce here in the United States through listing under the U.S. ESA would begin to erode that financial base of support. Is Congress willing to pick up the tab for exotic species conservation and captive breeding of these species?

If the addition of these fourteen species to the Endangered Species Act guaranteed substantial funding for the recovery and conservation of these species, then the benefits might outweigh the liabilities and detrimental effects on the captive breeding populations. Since there is no available funding, and no foreseeable source in this economic climate, then the liabilities severely outweigh the assets, as the genetic pool and diversity of these species in US aviculture and captive breeding programs would be severely, negatively affected.

All the Best,

Mark Stafford
President, Parrots International
mark@parrotsinternational.org
www.parrotsinternational.org
(310) 393-8317

The wildlife service is accepting comments and information concerning this petition [free PDF] regarding these 14 parrot species until 14 September 2009. To comment, write to:

Public Comments Processing
Attn: FWS-R9-IA-2009-0016
Division of Policy and Directives Management
U.S. Fish and Wildlife Service
4401 N. Fairfax Drive
Suite 222; Arlington, VA 22203

Comments will not be accepted by e-mail, phone or fax.