SSN comments on importation of
Amazona aestiva from Argentina
into the United States
Dr. Peter Thomas
Division of Management Authority
U.S. Fish and Wildlife Service
4401 North Fairfax Drive, Room 700
Arlington, VA 22203
October 6, 2003
Dear Dr. Thomas:
The Species Survival Network Working Groups on Bird
Trade and Wildlife Use jointly submit the following
comments in regard to the U.S. Fish and Wildlife Service's
(the Service) Proposed Rule for the addition of Amazona
aestiva in Argentina to the approved list of non-captive
bred birds under the U.S. Wild Bird Conservation Act
(WBCA) of 1992. Throughout our comments, Argentina’s
Management plan for Amazona aestiva is referred to as
We urge you to reject the proposed action for the following
1. Regarding the capture of adult and juvenile birds
The Plan provides economic incentives for farmers to
declare the species as a pest.
There is no basis for Argentina’s legal designation
of Amazona aestiva as a pest as crop damage caused by
the species is negligible (less than 1% (Navarro et
al. 1991)). We are concerned that, in allowing the harvest
of juveniles, the Plan promotes the use of lethal control
methods and provides an economic incentive for farmers
to declare the species as a pest, a view supported by
the Service in its Draft Environmental Assessment (2002).
Such takes are more likely to be based on financial
need rather than science.
The WBCA requires that for species that are considered
“pests” in the country of origin, such as Amazona aestiva,
the Plan shall include, “documentation that such a species
is a pest” (50 CFR 15.32 (6)(i)). Not only does the
Plan fail to include such documentation but field research
confirms that damage caused by the species is negligible
(Navarro et al. 1991)1. We believe that the species
would be best conserved by revoking its status as a
pest species, adopting a prohibition on hunting and
promoting safer, more effective control methods in agriculture
The Plan´s capture of adults and juveniles is not scientifically
based and risks overexploitation.
sets the capture quota for takes of juvenile and adult
birds at one-third the number of birds taken from nests.
Though the WBCA requires that the Plan be “scientifically
based” (WBCA Sec. 106 (c) (2)) and include “documentation
of how each level of take was determined” (50 CFR 15.32
(5)(iv)), no scientific information is provided on the
methodology used for setting quotas for this age group.
In addition, captured juveniles and adults may be from
the same populations that are subject to exploitation
in the nesting areas—seriously risking overexploitation.
In the Proposed Rule, the Service states that, “it is
unlikely that the flocks observed in the citrus groves
are those that nest on the properties participating
in the program” yet, experts state that seasonal movements
do occur and that “birds nesting in Argentine Chaco
move west to Andean foothills outside the breeding season
(Juniper and Parr 1998)”—the same areas included in
the management Plan.
We note, in this regard, that blue-fronted amazons are
actually more likely to prove serious crop pests in
the United States, where they lack natural predators,
than in their native habitat. Feral parrot populations
established by escaped pets have become seriously invasive
in several countries. In fact, imports of Amazona aestiva
itself are already prohibited in some jurisdictions
because of the threat non-native parrots pose to crops
and native wildlife.
The use of leg-snares to capture free-flying adult and
juvenile parrots is cruel and inhumane.
In the Service’s
Draft Environmental Assessment (2002), the Service expressed
concern about health risks for parrots associated with
using leg snares. These concerns have been deleted from
the Proposed Rule and, instead, the Service defends
the use of leg snares to capture juvenile and adult
birds by stating that “no birds were euthanized as a
result of injuries from leg snares.” The Proposed Rule
fails to reveal whether birds have been killed outright
by the traps (making euthanasia unnecessary); nor does
it consider the likelihood that injured birds may simply
be discarded outside the presence of program monitors.
2. Regarding the capture of nestlings
The Plan’s capture level for nestlings is not biologically
sustainable and will result in overexploitation.
levels for nestlings are based on the combined restrictions
of leaving one chick in each nest and a quota of two
birds per 20 hectares. Based on data available from
Proyecto Éle (Banchs, et al. 2000), the Service states
in the Proposed Rule that a nest typically contains
3 hatchlings, of which 2 nestlings survive to fledge.
Based on the information presented, the restriction
of leaving one chick in the nest to fledge would reduce
natural recruitment by at least 50%--hardly sustainable,
particularly for a species that continues to decline
through much of its range (Bucher 2000). ). This offtake
is in addition to substantial mortality rates chicks
will suffer due to natural factors. The combined impact
of direct harvest and natural mortality could lead to
complete failure in up to one-third of the harvested
The Plan’s estimated nest density for the species of
one nest per 20 hectares is more than 20 times greater
than previous estimates of nest density for the species
in Argentina (Bucher et al. 1995). The Plan’s estimate
is based on unpublished data that has not been peer
reviewed. The Service states that exports of the species
have not fulfilled the established quotas. This may
be an indication that the quotas exceed the productive
capability of the population.
The Plan does not take a cautious, conservative approach
in response to the lack of key biological information.
In the absence
of detailed biological information (population size
and range, habitat requirements, movement, estimates
of demographic rates, key factors that regulate population,
effects of environmental variation), Beissinger and
Bucher (1992) recommend the use of the Conservative
Sustainable Harvest Model (CSHM). This model allows
for the capture of excess birds produced by management
techniques proven to increase production of the species
such as, the use of nest boxes or by decreasing predation.
The Argentine Plan does not include efforts to increase
production. In addition, Beissinger and Bucher (1992)
state that the CSHM is only applicable to increasing
or stable populations; the model cannot be utilized
for a species such as Amazona aestiva which continues
to decline through much of its range (Bucher 2000).
3. Regarding Implementing legislation
We are concerned that the plan fails to address the
following important management and regulatory factors:
• The Plan does not include a mechanism to halt or reduce
captures if there is evidence that takes are unsustainable.
• The Plan provides no opportunity for objective and
independent monitoring and evaluation of the Plan. We
are concerned about possible conflicts of interests
for the managers of the Plan. It appears that the same
individuals whose available finances are dependent on
funds generated by the plan develop the quotas, conduct
the field research and, monitor populations and habitat
• The Plan includes no mechanism for evaluating the
level of compliance for so-called “preserved lands.”
• The WBCA requires that the plan ensures that “the
use of the species is biologically sustainable and maintained
throughout the range of the species in that country
to which the plan applies (emphasis added)” (WBCA Sec.
106 (c) (1)(B)) yet the Plan does not regulate the capture,
hunting, and sale of individuals of this species in
areas outside of the management plan or within the clearly
significant “folkloric” trade.
4. Additional requirements under the WBCA
All range States are not effectively implementing the
CITES Convention as required by the WBCA.
proposals for trade, the WBCA requires that the Secretary
“consider the adequacy of regulatory and enforcement
mechanisms in all contries of origin for the species,
including such mechanisms for control of illegal trade”
(WBCA Sec. 106(a)(3)(B)) (emphasis added). A species
may only be included in the list of approved species,
“if the Secretary finds the