Regulatory Forces Affecting Aviculture and the Pet Bird Industry AAV 1988

Susan L. Clubb, DVM Pet Farm, Inc.
5400 NW 84 Ave.
Miami, FL 33166

America - The land of the free and the home of the REGULATED. The beauty of the American way of life is freedom, self-determination and yes, regulation of virtually every aspect of our lives. Certainly the regulations, laws, treaties, customs and rules of ethics and etiquette allow us to co-exist in relative harmony. Too often however, regulations are written, passed and enforced by people who are not knowledgeable about the industry they are regulating, or not affected by said legislation. Dr. Walter Martin the president of AVMA (1988-1989) recognizes the importance of legislation to veterinarians and veterinary medicine and has shown this concern by proposng the establishment of a new Council of Legislative and Governmental Affairs.1

AAV has historically remained non-political and uninvolved in the regulatory process. Maybe it's time for this situation to change. We are challenged by regulations on all fronts - international, national, state and local. Our activities are affected by five governmental departments. The Department of Agriculture (USDA), the Department of Interior's (USDI) Fish and Wildlife Service (USFWS), the Department of Treasury (Customs), the Department of Justice (enforcement of regulations of other departments) and the Department of Health and Human Services (Public Health Service). The Public Health Service and Centers for Disease Control are primarily interested in psittacosis which will not be covered in this paper.5

In this paper I will attempt to summarize the major regulatory forces that now affect the trade and possession of birds in the United States. Each item mentioned contains volumes of information which cannot possibly be detailed here. The intention is to make AAV members aware of the complexity of dealing with a myriad of regulatory pressures.

INTERNATIONAL

International treaties, most notably CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora) regulate the movement of birds in international trade. There are other factors however that determine the availability of species for the pet trade. The majority of countries in which psittacine birds are found prohibit their exportation. Many export only pest species. Some are now operating under quota systems where pest species predominate. Most levy taxes on all birds exported.18'15

The Lacey Act, a US law enacted in 1908 "to supplement the State Laws for the protection of game and birds" has evolved over the years into a complex set of laws which prohibit the trade in any wildlife or wildlife product which is taken or possessed in contradiction of another law. This includes any species protected by foreign laws, international treaty, US laws, state or local ordinances or Indian tribal law. Species which are removed from their native country where they are protected, and imported from a second country, could be seized by USFWS and the importer prosecuted under the Lacey Act. The Lacey Act has been amended on several occasions. The Tariff Act of 1930 added the enforcement of foreign wildlife laws. A second major Lacey Act amendment in 1949, prohibited the importation of wild animals or birds under conditions known to be inhumane or unhealthful. The first truly comprehensive amendment of the Lacey act came in 1981. These amendments expanded and refined all aspects of the law including a strengthening of enforcement procedures.18

Simply stated, under the Lacey Act it is unlawful to import, export, transport sell, receive, acquire, or purchase in interstate or foreign commerce, any fish or wildlife or plant taken in possessed in violation of any state law, foreign law, treaty, or regulation of the United States or in violation of any Indian tribal law.15'18

These laws are enforced primarily by the US Fish and Wildlife Service (USFWS), a branch of USDI. The controversial new transport regulations, under the auspices of the Lacey Act, cover animals in international movement into the US.3

The Injurious Wildlife provisions of the Lacey Act prohibit importation, transportation, or acquisition, without a permit, of certain animals (or their eggs) which have been determined to be injurious wildlife.18

CITES (Convention on International Trade in Endangered Species)

CITES is an international treaty which currently has 95 signing countries including the United States which began implementing the treaty in 1975. CITES relates only to international trade in plants and animals and has no jurisdiction in internal affairs of parties to the treaty.8-19

International trade was recognized years ago as a major threat to many wildlife species. In 1963 the International Union for the Conservation of Nature called for an international treaty regulating trade and developed the first draft. 80 countries concluded the draft in March 1983 in Washington D.C. In 1975 the treaty was ratified by 10 of the original signatories in Beme Switzerland ( the depository nation for the convention ).8.13.19

The structures created by the CITES treaty include the Conference of the Parties (COP), the Secretariat, the Management Authorities and the Scientific Authorities. The COP meets every two years and has the power to adopt rules of procedure, approve the budget of the Secretariat, adopt changes to the appendices, and adopt recommendations to improve the effectiveness of the Convention. Within the COP exists a complex system of procedures and committees including the Standing Committee which assists the Secretariat in carrying out its functions and establishing the agenda and procedures for the meeting of the COP.13

The Secretariat was established by the treaty as a function of the United Nations Environment Programme (UNEP). UNEP is a UN body established by the Stockholm Conference on the Human Environment in 1972. It has a governing Council of slightly over 40 nations and serves essentially as a stimulator and instigator of environmental research, planning and management. For several years UNEP contracted out the secretariat function to the International Union for the Conservation of Nature (IUCN). The Secretary General and his staff are U.N. employees. The Secretariat is relatively independent and answers primarily to the Standing Committee and the Parties (COP). Each party country has a scientific and management authority.13

Plant and animal species are listed by CITES in Appendices I, II or III. Those species which are considered to be endangered are listed on Appendix I and no international commercial trade is permitted except under exceptional circumstances. Those species which are judged to be currently capable of tolerating commercial exploitation, but which may be threatened by trade are listed on Appendix II. All psittacine birds with the exception of the budgerigar, Indian ringneck, and cockatiel are listed on Appendix n, except those listed on Appendix I. Appendix III includes all species which any party identifies as being subject to regulation within it's jurisdiction for the purpose of preventing or restricting exploitation. Trade in any listed species, or products of a listed species, between signing countries, requires a permit.8'13'19

Procedures for amending the treaty or Appendices are complex. Any party to the treaty may propose an amendment, which must be submitted to the Secretariat at least 150 days prior to the meeting. The Secretariat then circulates the proposals with recommendations. Amendments are adopted by a 2/3 majority of those parties present and voting and enter into force 90 days later. The Berne criteria - adopted at the first meeting in 1976, established standards for the addition of species to Appendix I and II.19

Specimens of animal species in Appendix I bred in captivity for commercial purposes shall be treated as it they were Appendix II species (COP - Costa Rica - 1979). However in order for such trade to take place the breeding facility must be certified by the COP for each species involved (COP- Ottawa, Canada -1987). Currently only 1 establishment (in the world) is certified for 1 avian species.8

As CITES membership has increased, so have the number and complexity of issues the convention was established to resolve. Parties must make informed decisions as to the level of trade that populations of wildlife species can support, with insight into the biology and ecology of these species. Often producer countries lack the scientific expertise to make these decisions and they are made purely on political grounds. The next meeting is scheduled for the Fall of 1989, the final site selection is not complete. USFWS will invite proposals from within the US this fall via the Federal Register.8

International Air Transport Association (IATA)

IATA is an international organization of airlines established to standardize air transport policies. The 14th edition of the IATA Live Animal Regulations became effective on May 1, 1987. This 150 page volume has been developed in conjunction with CITES and with input from PUAC (Pet Industry Joint Advisory Council). It is sensitive to the needs of the animals as well as the Airline and pet industries. IATA has 119 active member airlines worldwide with 24 addition associate members, and 83 additional participating carriers. Sixteen countries (not including the US) have accepted these regulations either by legislation of by issuance of a permit authorizing air carriers to carry live animals in accordance with these regulations.20

These regulations contain information on virtually every order of animals from elephants to insects including classifications of animals, with detailed illustrations and descriptions of shipping containers. Other general information includes sections on animal behavior, lists of protected species, labeling requirements, disinfection of aircraft, feeding and watering requirements, sedation and euthanasia, segregation and persons accompanying shipments. The regulation book also contains an extensive section on CITES including a list of countries party to CITES and the management authority for each country.20

The IATA Live Animal Board is responsible for formulation and update of guidelines. The board meets every 2 years and invites representatives of trade, veterinarians, and other organizations to discuss problems and procedures. A new guide is currently in press with an appropriate section on birds with input from David Alderton, DVM, from England.6

NATIONAL LEGISLATION AND REGULATIONS

Endangered Species Act

The provisions of the Lacey Act are augmented by the U. S. Endangered Species Act (ESA) enacted in 1973, to halt the serious decline in numbers of many species of wild animals and plants. The ESA provides two levels of protection for listed species. Species considered to be in danger of extinction are listed as "Endangered" and are provided the most stringent protection. Species likely to become endangered are listed as "Threatened", and protected by less restrictive regulations. Administration of the ESA is shared by the USFWS and the National Marine Fisheries Service (NMFS).11,18

Commercial activities involving legally acquired endangered or threatened species that take place entirely within one's state of residence are not prohibited by the act. However, advertisements in publications that have interstate circulation must include a warning that an endangered/threatened species permit is required to purchase the listed animal. The Captive-Bred Wildlife (CBW) regulation became effective in 1979, making it easier to conduct activities that enhance the propagation or survival of eligible captive-bred wildlife listed under the ESA. To transport, deliver, receive, sell, or offer captive bred specimens for sale in interstate commerce under the CBW, both the buyer and the seller must be registered for the families of wildlife involved. Each transaction must document that the animal was born in captivity in the United States and the buyer's and seller's CBW permit numbers.11,18

Twenty-six species of psittacines are included in the list of Endangered and Threatened Wildlife and Plants and covered by the act ( 50 CFR part 17.17 ).11'12

Importation of Birds

The importation of birds falls under the mandates of three Departments. They are subject to quarantine regulations under the Department of Agriculture's Animal and Plant Health Inspection Service - Veterinary Services, (USDA-APHIS-VS) regulations (50 CFR part 9). The quarantine system was discussed in detail in a paper presented to AAV in 1988 and will not be covered here.10,12,20

They also come under the scrutiny of the Department of Interior under the auspices of the US Fish and Wildlife service enforcement of the Lacey Act, Endangered Species Act and CITES treaty. CITES export permits must be presented along with the "Declaration of Importation" form (filed by the importer or his broker shortly after arrival) and the USDA Permit to port Birds. The numbers and species of birds are then feed into the USFWS "LEMIS" data system for correlation. If they do not agree or there is suspicion of non-compliance with any regulation, the country of origin is contacted through the State Dept. If there is reason'to suspect misidentification FWS agents will enter a station to inspect.10,12

In addition they must pass inspection by US Customs, Department of Treasury. Most exporting countries are economically disadvantaged and therefore fall under the GSP (Generalized System of Preferences) program or Caribbean Basin Economic Reform and are therefore exempt from tariffs, however Customs officials inspect incoming shipments to assure compliance with USDA and USDI import regulations.

Animal Welfare Act

The animal welfare act as administered today by the US Department of Agriculture evolved over the years from the original laboratory animal welfare act of 1966. Veterinary Services (VS) office of USDA, Animal and Plant Health Inspection Service (APHIS) is assigned responsibility for the performance of functions under the act. Covered under the act are any live or dead dog, cat, non- human primate, guinea pig, hamster, rabbit of any other warm blooded animal which is domesticated or wild, and being used for research, testing experimentation, exhibition or as a pet. Excluded are birds, rats, mice, horses and other farm animals such as poultry and livestock. Animals are covered in research facilities, in commerce, pet stores, exhibits of all types, and breeding facilities.1

While the main emphasis is on cats and dogs the act can have far reaching effects depending upon the personality of the enforcement inspector. The act requires licensing of any person operating as a dealer or exhibitor or person operating an auction sale. A person licensed as a dealer or auction operator must report annually all sales and the total dollar amount of sales (in order to determine licensing fees). A person registered as an exhibitor shall report annually the number of animals held.2

The act requires registration of research facilities, carriers and intermediate handlers. Research facilities must submit and annual reports including the total numbers and types of animals upon which experiments and tests were conducted, breaking down those procedures which entail pain or no pain to the animal, including the use of anesthetics, analgesics, etc. Routine injections, blood collection and tattooing need not be reported. Each animal must be identified by an approved method for that species (most with an official tag). Also included in the act are extensive regulations governing housing, disease control, transport, housekeeping, law enforcement, some aspects of veterinary care especially in regard to anesthetics and analgesics, employees, pest control, and virtually any other aspect of captive animal management.

Animals held under treatment by a veterinarian are currently exempt but this position is subject to change. There are also references in AVMA literature which would suggest bringing all warm blooded animals under the act, exempting farm animals. The enactment of this law greatly increased the cost of animal research. In conjunction with the federal permit system, it has also virtually eliminated private breeding of primates in the U.S. It's application to birds could be very costly for American aviculture.

PENDING LEGISLATION AND REGULATIONS

Federal Permits to Possess Wildlife (USFWS)

Part 13 of title 50 code of federal regulations provide for the general administration of permits issued by the service (Fish and Wildlife Service). A new proposed rule purports to clarify the application procedures and the criteria. The service further has proposed changes in part 21 of 50 CPR relative to permits issued under authority of the migratory bird treaty act.

The service has proposed significant changes in part 21 of 50 CFR relative to permits issued under authority of the migratory bird treaty act The service has proposed significant changes to the falconry and raptor propagation permit regulations. Other changes in part 21 include amending the special purpose permit regulations to allow sale of captive bred, migratory game birds other than waterfowl. In addition, the service intends to re-impose the requirement for permit to import and export certain migratory birds.

Model State Regulations

The model for State Regulations pertaining to Captive Wild and Exotic Animals addresses interstate movement, sale possession, exhibition and release of captive wild and exotic animals. The model is intended to be adopted in part or in it's entirety by individual states which are updating wildlife laws. Disease prevention and control measures are intended to protect the health of captive wild and exotic animals as well as domestic livestock, poultry, native wildlife and humans. Minimal animal care standards are provided. The model plan also deals with the permitting process covering such issues as who needs them, who grants them, denial, suspension and revocation, what birds require permits, standards, etc. The model plan makes the distinction between personal possession, hobbyist collector/propagator, and Animal Dealer/Commercial propagator. Auction, and Exhibitors.

The model is being prepared by Dr. Victor Nettles of the Southeastern Cooperative Wildlife Disease Study at the University of Georgia College of Veterinary Medicine. He is now in the process of writing the third draft. It will then be forwarded to USDA. They will either reject it and send it back to Dr. Nettles or accept it and send it to the US Animal Health Association (USAHA) for consideration.4,24

Lacey Act - Regulations for the Humane and Healthful Transportation of Animals

In November 1988, 50 CFR part 14 - humane and healthful transport of wild animals and birds into the United States was published as a final rule but was postponed following a meeting between USFWS and a group representing airlines and animal dealers. FWS subsequently postponed the Feb. 8 implementation date until Aug. 1 1988 so the rules could be amended. The humane community, led by the Humane Society of the US, then brought a lawsuit seeking an injunction against USFWS to force them to implement the regulations as written. This was an attempt to halt legal importation by making it prohibitively expensive to ship birds into the US. The injunction was granted by a judge, and apparently the regulations are in effect USFWS has directed that they be enforced prudently. According to official notice published in the Federal Register, FWS recognizes that there may be special circumstances where strict compliance with these regulations would not be in the best interest of wildlife or "... would be highly impracticable." Exceptions are permitted and will be monitored by FWS law enforcement agents on a case by case basis. Violations which the FWS determines could result in harm, distress, injury or death to the animals are subject to prosecution.3,9

On August 10, 1988, the USFWS published in Federal Register it's intention to propose amendments to these regulations and opened a comment period.16

State Bird Ban Laws (Bans on the Sale of Imported or Wild Caught Birds)

Since the surprise enactment of a ban against the sale of wild caught birds in New York State in 1985 (became effective in 1986), similar legislation has been introduced around the country. Critics of the New York bill predicted the emergence of smuggled birds and concurrent introduction of disease into the state if the bill was passed. In 1987, New York was one of 6 states in which WND was diagnosed in association with smuggled Yellow Naped Amazons.4,5,6,8,17

The avian quarantine program was specifically designed to ensure the protection of poultry. Maintenance of this program is essential to prevent the introduction of avian disease. In a letter from Bert Hawkins, USDA - APHIS administrator, dated April 3, 1985, the USDA position is stated as follows: "It would appear that such bans would be difficult to enforce and may result in an increase in the number of birds being smuggled into the United States. Since smuggled birds are not inspected and tested for exotic poultry diseases, an increase in smuggling would increase the risk of introducing diseases which could result in severe economic damage to the U.S. poultry."17

Following is a listing of similar legislation is other states.4,5,8,6,17

Pennsylvania - House Bill 2227. A hearing was held in May, 1988 on the pending bird ban bill. Representatives of the American Federation of Aviculture (AFA), Pennsylvania Federation of Aviculture, PUAC, Pennsylvania Department of Agriculture, Pennsylvania Poultry Federation, Pennsylvania Game Breeders, a Penn State University Extension veterinarian and attended and testified against implementation of the bill. The bill is now pending and will probably be acted upon in the fall.

Michigan - a bird ban bill was planned for introduction this year.

California - Assembly Bill 3397. A bill which directs the Department of Fish and Game to prepare and submit a report to the legislature on the sale and trade of captured wild birds in the state passed the Assembly and is now under consideration by the Senate. AFA members have requested amendments requiring the study of the positive aspects of aviculture be added to the bill.

Utah - A proposed rewriting of state wildlife regulations will divide all wildlife species into three categories - prohibited, controlled or non-controlled. Unlike other animals covered in this proclamation, all birds not listed as controlled or non-controlled will be considered prohibited. All transactions involving birds will require a permit, even a child selling budgies to a pet store.

Arizona - Wildlife laws are under revision. New York style bird bans may soon be introduced in Georgia, Wisconsin, Washington and Minnesota. Informed sources suspect a generic bill is being circulated by local chapters of the Audubon Society with blanks to fill in the name of the state, bill number and dates.4'5

New Jersey • Bill was tabled in committee in 1986.

Massachusetts - Bill was sent to a summer study group in 1986 and has remained there. By regulation any bird on CITES Appendix I or in the IUCN Redbook require a permit for possession.

Connecticut - Bill was sent to a summer study group in 1985 and has remained there.

Illinois - Bill was introduced and successfully fought by aviculturists - bill was withdrawn by sponsor in 1987.

Maryland - Bill was defeated in 1986.

Local - City and County Ordinances

Local zoning ordinances may pose the most immediate danger to the possession of birds. City and County ordinances may also prohibit ownership of a variety of animal and bird species. These ordinances, as well as state laws restricting ownership of certain species are detailed in the Controlled Wildlife Series.23

Improvement Plans

In 1983, a small group of workers, inspired by the highly successful, voluntary, National Poultry Improvement Plan (NPEP) attempted to develop a similar program for pet birds. Despite intensive efforts the plan was greeted with suspicion by aviculturists as government intrusion into their aviaries. While widely accepted now NPIP was likewise poorly accepted initially.

The Maryland Cage Bird Improvement Plan (MBIP) was approved by the Maryland State Legislature in 1986. It is a voluntary, self-governing program developed by breeders, pet shops, and veterinarians in association with the University of Maryland Cooperative extension service, Maryland Department of Agriculture, Maryland Department of Health and Hygiene, the Poultry Industry and the State Legislature. The MBIP is now functioning with an inspector and 13 members. Virginia is planning a similar improvement plan.7

The Florida Cage Bird Improvement Plan was formed in 1987 and is modeled after the Maryland plan with the addition of sections on handfeeding. This plan was organized by a group of aviculturists and at the time of writing has not involved any State of Florida agencies. The group of 24 members includes aviculturists, pet shops and pet owners and two inspectors.14

Humane and Conservation Groups

Many large and powerful humane and conservation groups influence elected officials in all levels' of the government and serve as watchdogs over the industry. Some are hostile to the pet trade and feel birds should not be kept in captivity (such as Audubon Society). Others, such as the Humane Society of the US are concerned primarily with humane treatment but want to stop importation of birds.

IUCN (International Union for the Conservation of Nature and Natural Resources), founded in 1948, is a network of governments, non-governmental organizations, scientists and other conservation experts, joined together to promote the protection and sustainable use of living resources. IUCN monitors the status of ecosystems and species around the world, plans conservation action, promotes such action by governments and provides assistance and advice necessary for achievement of such action.25

IUCN Trade Specialist Group (Center for Environmental Education in Cambridge, England) reviews proposals to CITES for adequate trade and scientific data and makes recommendations to the COP. IUCN also publishes the Red Data Book (lists of endangered species) and the Significant Trade in Wildlife Reports.25 (see also bibliography)

UNEP (United Nations Environment Programme) was established in 1972. It's mandate is to keep the world environmental situation under review in order to ensure that emerging environmental problems of international significance receive appropriate consideration by governments, and to safeguard the environment for the benefit of future generations. The ultimate aim of UNEP'S activities is to promote development that is environmentally-sound and sustainable.25

WWF (World Wildlife Fund) is an international conservation foundation based in Switzerland. WWF's scope is the conservation of the natural environment and the ecological processes essential to life on earth. WWF aims to create awareness of threats to the environment and to generate and attract on a worldwide basis the strongest possible moral and financial support for safeguarding the living world. WWF, with it's international and national trustees, also provides a bridge for the conservation movement to the business community. WWF through it's subgroup Traffic (Trade Records Analysis of Flora and Fauna in Commerce) monitors trade and has played a major role in the development of CITES.25

The World Conservation Strategy (1980) is a plan prepared by IUCN, with advice cooperation and financial assistance of UNEP and WWF. It provides an intellectual framework and practical guidance for conservation actions needed to conserve living resources for sustain-able development. It details major threats to the environment, the obstacles to achieving conservation, the strategy to solve conservation problems and an international plan to coordinate use of the global commons and the requirements for sustainable development.

The International Council for Bird Preservation (ICBP), based in Cambridge England predates IUCN but now primarily handles bird related issues for IUCN. It's parrot specialist group will meet in Brazil in October 1988.6-26

Pet Industry Joint Advisory Council (PIJAC)

PUAC, through it's Council Marshall Meyers, is the only unified voice of the pet industry. A non-profit organization based in Washington, PUAC monitors legislation adverse to the pet industry, provides information to industry members, represents the pet industry to governmental agencies and conservation groups and serves as a lobby for pet industry interests. PUAC has been an non-governmental observer to CITES since 1979 and in CITES transport working group and CITES high trade study.6

American Federation of Aviculture (AFA)

AFA was founded in 1974 in response to USDA control measures initiated by the epomitic of Viscerotropic Velogenic Newcastle Disease. The stated goal in 1974 was to stop the needless destruction of birds by USDA in it's attempt to control WND. The stated purpose of AFA is - Conservation of avian life through encouragement of captive breeding programs. Scientific research, education and the monitoring of legislation affecting aviculture. AFA is a national organization based in California and holds an annual educational meeting.

DISCUSSION

Can we (AAV) afford to turn our backs on legislation, regulations, treaties, or ordinances which could deprive us of our birds, our clients' birds, our avocation and our vocation? AAV, as a professional organization, has the kind of respect which can make our combined voices be heard. applaud the efforts of a few dedicated individuals such as Gary Lilienthal, Janet Lilienthal. Lee Phillips, Marshall Meyers and many others who are fighting our battles, so we can keep, breed, study and enjoy the wonder of the avian community. But we shouldn't expect them to carry the banner alone.

The combination of permit restrictions, transport restrictions, zoning ordinances, even assumptions from within and without that we should not be allowed to possess, breed, or exhibit birds could stagnate small populations of birds with limited genetic diversity, at the same time that habitat destruction proceeds unabated. Where is the future for our birds, our clients? Maybe someday we can write extensive books on the diseases and disorders that we can treat, cure or prevent in birds which we will only see in picture books or which are extinct due to the combination of habitat destruction and lack of captive propagation.


What can AAV, or individual members of AAV do to help? The first step is to become involved. Regardless of your personal views, a sharing of all ideas is helpful. Get to know the avicultural and pet industries and keep abreast of legislative and regulatory issues.

Work with aviculturists, pet shops, and dealers to improve management and husbandry practices which will in turn help reduce the need for regulation at the local and state levels. Give constructive advise to improve standards and knowledge. When aware of legislative or regulatory threats - RESPOND - by writing or phoning the appropriate individuals or offices. Take the opportunity to become more aware of regulatory mechanisms which affect your clients, the veterinary community, importers, pet shops, aviculturists and the pet owning public.

And finally we can embrace the World Conservation Strategy - an international strategy for the maintenance of essential ecological processes, preservation of genetic diversity and sustainable utilization of species and ecosystems.


Appendix 1

FOR FURTHER INFORMATION

American Federation of Aviculture. P.O. Box 1568, Redondo Beach, CA 90278

Department of Agriculture - Veterinary Services, Animal and Plant Health Inspection Service, U.S. Department of Agriculture, Federal Building, Hyattsville, Maryland 20782 301-436-8170

Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) - 6 rue de Maupas, Case Postale 78, CH-1000 Lausanne 9 Chanderon, Switzerland.

Florida Cage Bird Improvement Plan - Donna Vickers, President -2117 W. Palma Circle, West Palm Beach, FL 33415

International Air Transport Association, IATA Building, 2000 Peel Street, Montreal, Quebec, Canada H3A 2R4

International Union for the Conservation of Nature and Natural Resources, 1196 Gland, Switzerland. Maryland Cage Bird Improvement Plan, P.O. Box 2826, Laurel Maryland 20708

Model for State Regulations pertaining to Captive Wild and Exotic Animals, Dr. Victor Nettles, Southeastern Cooperative Wildlife Disease Study, College of Veterinary Medicine, University of Georgia, Athens GA 30602

Pet Industry Joint Advisory Council (PUAC) - 1710 Rhode Island Ave., N.W., Washington D.C. 20036 1-800=553-PETS

Traffic (USA) - World Wildlife Fund. 1255 Twenty Third St., Washington, D.Q 20037

U. S. Fish and Wildlife Service, Division of Law Enforcement, P.O. Box 28006, Washington, D.C. 20038-8006.

Federal Wildlife Permit Office, P.O. Box 3654, Arlington, VA 22203 703-235-1903

Department of Health and Human Services -Division of Quarantine, Center for Disease Control, Atlanta, GA 30333

BIBLIOGRAPHY - FOR FURTHER READING

Endangered Birds of the World, The ICBP Bird Red Data Book, Compiled by Warren B. King - Smithsonian Institution Press, Washington D.C. 1981.

Controlled Wildlife, A Three Volume Guide to U.S. Laws and Permit Procedures. Published by the Association of Systematics Collections, Museum of Natural History, Dyche Hall, University of Kansas, Lawrence, KS 66045, 1984.

Volume I - Federal Permit Procedures -Carol Estes and Keith W. Sessions

Volume II - Federally Controlled Species -Carol Estes and Keith W. Sessions

Volume III - State Wildlife Regulations -Steven King and J.R. Schrock

Significant Trade in Wildlife: A Review of Selected Species in CItES Appendix n. Volume 3; Birds., Tim Inskipp, Steven Broad and Richard Luxmoore. Compiled by IUCN Conservation Monitoring Centre. 219c Huntington Road, Cambridge, U.K., 1988.

The Evolution of National Wildlife Law; Michael J. Bean, Praeger Publishers, CBS Educational and Professional Publishing, 521 5th Ave, New York, NY 10175, 1983.

The Endangered Species Handbook, 2nd Ed.; Greta Nilsson, Animal Welfare Institute, P.O. Box 3650, Washington, D.C 20007, 1985.

The Bird Business - A Study of the Commercial Cage Bird Trade, Greta Nilsson, Animal Welfare Institute, P.O. Box 3650, Washington D.C 20007.

Endangered Parrots, Rosemary Low, Blandford Press, Link House, West Street, Poole, Dorset BH15, ILL UK, 1984.

Parrotletter - The Newsletter and Journal of the ICBP/SS Parrot Specialist Group, Volume 1, Number 1 - For Info write - Don Bruning. New York Zoological Society, Bronx Zoo, Bronx, NY 10460.

CITES -Identification Manual (5 Volumes) - Volume in - Aves Editor Peter Dollinger -Secretariat of the Congress on International Trade in Endangered Species of Wild Fauna and Flora, Lausanne, Switzerland - 1985.

Proceedings of the Conference of the Parties (CITES)

1st Meeting - Berne, Switzerland 1977
2nd Meeting - San Jose, Costa Rica 1979
3rd Meeting - New Delhi, India 1981
4th Meeting - Gaborone, Botswana 1983
5th Meeting - Buenos Aires, Argentina 1985
6th Meeting - Ottawa, Canada 1987

Estimating Numbers of Terrestrial Birds, Editors -John Ralph and J. Michael Cooper Ornithological Society, Alien Press Inc., P.O. Box 368, Lawrence KS, 66044.

REFERENCES

1. AVMA Convention News, 125th Annual Meeting of AVMA, Portland Oregon - July 17, 1988.

2. 9 CFR Ch. 1 (1-1-85 Edition) Animal and Plant Health Inspection Service, USDA Subchapter A - Animal Welfare

3. 50 CFR part 13 - Lacey Act, Humane and Healthful Transport of Animals

4. Lilienthal, Janet - Legislative Vice President, American Federation of Aviculture

5. Lilienthal, Gary - Legal Council, American Federation of Aviculture

6. Meyers, Marshall - Pet Industry Joint Advisory Council

7. Maryland Cage Bird Improvement Plan, P.O. Box 2826, Laurel MD 20708.

8. Phillips, Lee - CITES Committee Chairman, American Federation of Aviculture.

9. Pet Business Magazine. Vol. 14, No. 8, July 1988.

10. Clubb, S. The Pet Bird Industry • Past Present and Future - Proceeding of AAV, 1987.

11. 50 CFR part 17.11 and 17.17 - List of Endangered and Threatened Wildlife and plants.

12. Dixon, Alexandra M. -Evaluation of the Psittacine Importation Process in the United States. Commissioned by; TRAFFIC (USA), World Wildlife Fund, 1255 Twenty-third Street, NW, Washington, D.C. 20037

13. Parsons, Richard M; The Structures of CITES

14. Vickers, Donna - President, Florida Cage Bird Improvement Plan, 2117 W. Palma Cir., West Palm Beach FL 33415 - Personal Communication.

15. 16 U.S.CA. 3101 to End (Chapter 53 -Control of Illegally Taken Fish and Wildlife).

16. Federal Register/ Vol. 53. No. 154 / Wed. August 10, 1988. Proposed Rules. Humane and Healthful Transport of Wild Mammals and Birds to the United States.

17. Facts about pet birds; Pet Industry Joint advisory Council, 1710 Rhode Island Ave., N.W. Washington, D.C, 20036.

18. Evolution of National Wildlife law (Bibliography)

19. CITES -A Conservation Tool - A Guide to Amending the Appendices to the CITES -Prepared for the 5th meeting of the COP -Ottawa Canada. IUCN SSC Trade Specialist Group, 1725 DeSales St N.W. Suite 500, Washington, D.C. 20036.

20. International Air Transport Association, Live Animal Regulations., 14th Edition, 2000 Peel Sfc Montreal, Quebec, Canada H3A 2RA

21. 50 CFR, part 9 - Federal permits to possess wildlife

22. Ireland, Tom - Personal communication

23. Controlled Wildlife Series (see bibliography)

24. Model State Regulations pertaining to Captive Wild and Exotic Animals, Southeastern Cooperative Wildlife Disease Study, College of Veterinary Medicine, Athens, GA 30601

25. World Conservation Strategy -International Union for the Conservation of Nature and Natural Resources, 1196 Gland, Switzerland.

26. Parrotletter - International Council for Bird Preservation/ Parrot Specialist Group - Vol. 1, No. 1, New York Zoological Society, Bronx Zoo, Bronx, NY 10460.