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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 “the Plan”.

We urge you to reject the proposed action for the following reasons:

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 areas.

The Plan´s capture of adults and juveniles is not scientifically based and risks overexploitation.

The Plan 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.

Capture 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 nests.

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 conservation.
• 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.

In evaluating 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