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I am in receipt of a copy of your Bill HR 4958, to promote the "Conservation of exotic wild birds".

I think that it is best to first explain my association with
exotic birds. I am, and have been, an avid breeder of
exotic birds for almost 10 years. During the course of my
relationship with the exotic birds in 1986, I donated
$1,000,000.00 to Texas A & M for the establishment of the
worlds only independently endowed fund created exclusively
and solely for the scientific exploration into the cures of
diseases and viruses of the exotic birds. Texas A & M
matched the donation, giving us a $2,000,000. fund and built
for us, in addition to the money, labs, aviaries and
furnished equipment to operate the center which is called
the "Schubot Exotic Bird Health Center". No other entity,
public or private has done as much for the exotic bird.

Additionally, I am involved in several conservation projects:

1) The return of the Thick Bill parrot to the wild (it being the only exotic type bird indigenous to the U.S.A. Since the dying of the Carolina Parakeet in 1911. Our participation is with the Federal Fish & Wildlife and the state of Arizona Fish & Wildlife. This past year (fall of 91) 20 parrots were put into the wild for repopulation, and all of them except for four died. Ours were recovered and brought back to a holding area in Arizona. This in itself helps depict our expertise in the field of aviculture.

The

2) We returned a group of Military Macaws into the mountains of Guatemala after an absence of 110 years. National Audubon Society thought this effort to be worthy enough to make it its' for the 2nd Quarterly issue of American Birds, its' front cover publication and lead story of the issue.

3) We are breeding the Rothchild Minah (Bali) for the re-introduction into the forest in Indonesia.

1471 Folsom Road, Loxahatchee, Florida 33470 (407) 793-5135 FAX: (407) 790-1317

4) We did a massive Juvenile blood study into baby macaws, cockatoos, and eclectus which was referee written by Avicultural Breeding & Research Center so that the

veterinary world would have a base line judgement for the blood values of the juveniles of ages 30, 60, 90 and 180 days.

In addition to all of this, we have just completed a comprehensive book written for the education and the care, knowledge with special scientific studies into blood, weight development and growth factors of babies.

We were also featured on April 24th on Americas Most Wanted to show our work in Aviculture as opposed to smuggling.

We are considered the experts of the world in the care, knowledge and breeding of the Palm Cockatoo.

With all of this as a background, I believe what I am about to critique should be considered. First, I would like to suggest a few thoughts as to the written bill then conceptually a few ideas.

Page 1 11th line, add "or" after "and". The reason being that it could be sustainable in the wild and can be better sustained in captivity to preserve the species. Cockatoo is a prime example.

Page 2, line 25

world country not

The Palm

How to reward for loss of income in a 3rd exporting to preserve.

Page 3 (5) line 5 Where is the written criteria vs criticism?

Page 7 (F) + (G) sections?

Where is the justification of these 2

The United States Department of Enforcement of the Fish & Wildlife division cannot control smuggling with all of its money and expertise. The Mexian Amazon comes into the United States by the tens of thousands and Palms come right down the four lane highway between Tiauana and San Diego unhindered. How do we have the audacity to say a country like Indonesia (as has been said by the Fish & Wildlife Department of Scientific Authority), that it cannot protect its' birds with thousands of miles of ocean frontage, no Navy or Coast Guards. What would one expect?

In regards to (G) the Indonesian Government. It is building a new city in the area of the Palm Cockatoo Goliath subspecies to alleviate the crowded miserable living conditions in Jakarta. This area is known as Irain Java. Should the people live in squaler versus new housing.

Page 8 (I)- Who is going to pay in the case of 3rd World countries to implement this paragraph and how long is it going to take to implement it?

Page 8 (2) (C) The wording is confusing.

This is a three

year plan not a four year as it appears to imply. first year 75%, second year 50%, third year 25%, and 4th year 0. It takes three years to reach ZERO.

Page 9 (A) (iii) After sustainable add "or not", and if not then protect the bird before it becomes extinct.

Other than these minor conditions the bill is functionally good. However, conceptually we need to look at several

areas:

1) The Third World countries need money and I am told 55 of them threatened to succeed from the convention. If they cannot sell their natural resources, where do they get help?

2) We need to consider the restocking of breeder birds in an intelligent manner. In the case of Appendix I, perhaps by virtue of expertise of breeders.

3) The need to set up "breeding farms", not ranching in a given number of years.

We had started a personal program with the Department of Forestry of Indonesia and had trained a veternarian for six months and then on the agenda was the training of their keepers, and then go over to Indonesia to help establish the breeding farms. I am hoping to meet with Sutisimo Wartiputra, the Minister of Forestry, at the end of this month to put our program back into effect.

Thank you for taking the time to read this letter and I hope to hear from you regarding this matter. I will be happy to attend any hearing regarding this Bill.

Very tru yours,

RICHARD M. SCHUBOT

RMS/pc

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I am writing concerning bill H.R. 5013 which is up for a hearing before your Committee. There are a number of things in this bill which I feel are not a help to those of us who are concerned with aviculture. I am not very happy with this bill being drawn up by the Fish & Wildlife personnel because the bill shows their bias of bureaucratic importance and the desire to control a hobby they have long cherished to control. With personnel from the "other" side of the fence, as paid government emplyees, it is easy to see how yet again the citizens of this country are being told to accept what the special interest groups, both within and without the government, want for all the rest of us. Quite frankly Congressman of all three bills that have been before your Committee this year and last it is quite clear that only the Cooperative Working Group on the Bird Trade prepared by the World Wildlife Fund is still by far and away the best and fairest to all concerned.

Now to my comments on the "Wild Bird Conservation Act of 1992".

I

1. As I read the bill this Act does not preclude that individual states can still pass additional legislation pertaining to imported birds. urge you to make sure that this Act is pre-emptive of all state laws in regards to the contents of this Act. To do otherwise is to pile more bureaucratic rules on serious aviculturists, even to the point where we could be placed in a position that we could maintain only a few "domesticated" species.

2. It is also interesting to note that under the section dealing with definitions that no such appears for the term "cooperative breeding program which appears throughout the Act. In the definition it should include the term - Speciality Avian Organizations, such as the International LORIINAE Society and the AMAZONA Society (and others) who have actively been involved with breeding birds and have set up studbooks on a world wide bases to maintain the gene pools of various species. To not include these groups would be a major injustice to those of us who have spent a number of years working along these lines to secure captive breedng groups with pure blood lines.

3.

In section 5 (b) (1) (C) this is an arbitrary statement. As an example. If I choose to import some Fairy Lorikeets for the ILS studbook breeding program and the species appears on the list I am unable to do

So.

Now I will concur that if these birds are going to be imported by

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a commercial importer that the mortality rate might be high. However, if I would be importing them I would make sure that the birds were' in good shape BEFORE I either shipped them myself or had them shipped. Therefore I feel strongly that some provision should be made in the Act for qualified individual aviculturists or small commercial dealers who bring in ONLY small shipments for zoos and private breeders should be excluded from the provision.

4. Under annual quotas there is no provision for importing birds that were not imported during the preceeding 5 yeras. As example, ILS is negociating to import a species of lorikeet which has not been imported before. The birds will be owned by ILS but will placed in selected breeders hands. These birds will be managed in a studbook by ILS. To say that these birds could not be imported because they had not been imported before is not in the interest of the bird species to be worked with.

5. The List of Approved Species is quite frankly a joke. If the species are listed in the Appendices to the Convention then they can not be imported. What about captive bred specimens of Appendices species ? The Act also insists that EVERY species have a management plan before it could be imported. This Congressman is ludicrous. That is good away of saying there will be no more imports. As you must know, there are not enough qualified people in the majority of countries, let alone the money to set up a management plan for every species. It would be easier to just say that no more birds will be imported.

6.

Under Exemptions it was interesting to note that no provision was for Speciality Groups under the cooperative breeding programs section. I mentioned this above and it should be included here aw well.

In addition it is also interesting to further note that no mention has been made for farming or ranching in the country of origin of the birds that a country may choose to export and which therefore we could import. Both of these options are viable and must be considered, as long as there is a scientific study to support such an option.

7.

I commend you on the inclusion of Sec. 11 Fund. A brillant move.

Exotic Bird Conservation

Congressman it would seem that since much of what is in the Act was rejected at the recent CITES Conference in Japan that in order to show everybody just how tough we are that we will dam well do what we want to do regardless of what others think. As I said in the begining this bill is worst than the 2 bills you had before your Committee last year. If the above changes are made to the bill I would support it regardless of by personal feelings and those of ILS.

Finally Congressman I would like it placed on the record that although I support some solid control on bird importations, I caution that a total ban will not serve the cause of international conservation. If birds are not worth something to the people who get some money from the trade then the only thing they have left to sell is their forest, and that we really can not tolerate.

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Jan Roger van Oosten

Conservation Chairman

Also Editor and Special Projects Chairman for the AMAZONA Society.

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