I oppose listing the hyacinth macaw. I view listing as a perversion (noun: The alteration of something from its original course, meaning, or state to a distortion or corruption of what was first intended) of the Endangered Species Act (ESA) and unnecessary, redundant legislation for the following reasons:
1) The hyacinth macaw is already listed and protected under CITES, which the U.S. honors in accordance with Section 2.a.4.F of the ESA.
2) The proposal does not in any way support the purpose of the ESA as defined in Section 2b, as there are no discrete conservation programs associated with this listing, making the listing arbitrary and superfluous in nature, as the U.S. government already supports CITES.
3) The proposal, through lack of associated conservation programs, and by negatively impacting current breeding activities (hence conservation) of the hyacinth species in the US by unnecessarily increasing permitting and restriction of ownership, clearly does NOT support ESA policy defined in Section 2(c).
4) The proposal, through loss of breeders and owners (you can't successfully breed unless there is an outlet for production) would contribute to the further decline of total global hyacinth population, shrinkage of the gene pool in remaining breeding population, loss of small businesses dependent upon the small but viable hyacinth industry, loss of public awareness for conservation efforts, ecotourism, and conservation donations, to name a few of the down road impacts.
5) Most importantly, U.S. listing would do nothing to conserve the hyacinth in its home range of Brazil, Paraguay, and Bolivia or further hamper unsustainable exploitation resulting from remaining illegal trade in those countries. All impact would be negative for the U.S. owners, breeders, and birds (birds would suffer if their firmly established bird-human bonds were severed) of the current U.S. captive hyacinth population. I see no winners in this proposal.
Submitted Electronically via eRulemaking Portal
This is comment on Proposed Rule
Endangered and Threatened Wildlife and Plants: Listing Three Foreign Macaw Species
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