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Since 2008, when the U.S. Fish and Wildlife Service first implemented the "validation" requirement for shipments of wildlife and wildlife-related material imported under CITES permits, scientists have had difficulty importing research materials. Though the USFWS had made extensive efforts to reach out to the other nearly 180 CITES countries to explain the validation requirement, it proved that many countries seemingly lacked the will or ability to comply. As a result, shipments into the U.S. often lacked validation entirely or the validation was somehow deficient. The shipments were rejected and either destroyed or returned to the country of origin. In some cases, material deteriorated or was lost when returned.
Beginning in 2009, the Ornithological Council began to contact the USFWS Divisions of Law Enforcement and International Affairs. The USFWS was at that point disinclined to take action, but suggested that the OC continue to track problems and bring them to the attention of the USFWS. In addition, the OC began to advise ornithologists to take extreme care to assure that validation be obtained and done correctly. These measures included determining the name and location of the officials at the airport who could validate shipments and making appointments to meet with those officials. Nonetheless, problems continued. Ornithologists who followed this advice would arrive at the airports in some countries only to be told that validation was not necessary. At other airports, only one individual was authorized to validate shipments and that individual would not be present, notwithstanding the fact that an appointment had been made. More frequently, the validation was not done correctly.
In January 2013, the OC asked Dan Ashe, the Director of the USFWS, to look into the problem. He referred the matter to his Assistant Director for International Affairs and the USFWS Chief of Law Enforcement. After a meeting in February 2013, the OC continued to bring validation problems to the attention of the USFWS. Unfortunately, this meeting and follow-up communications brought about no resolution. As a result, the OC, together with the American Society of Mammalogists and the Society for the Preservation of Natural History Collections on 8 April 2014 filed a petition to the Secretary of the Interior, formally asking that the validation requirement as to scientific shipments be suspended or revoked.
The petition (attached) explains that "... we understand the need for effective enforcement and we would not seek an exception to this important rule without a good reason. The fact is that, at least with scientific research material, the validation procedure has not proved effective...Scientists are keenly aware of the need to protect wildlife and make every effort possible to avoid having an impact on populations of wildlife. Much, if not most, taxonomic study and other research involving wildlife can be undertaken with museum specimens or blood or tissue samples, which may also be taken from natural history collections rather than collected from wild animals. In many cases, there is no need to sacrifice additional live animals. Moreover, it is exceptionally difficult to obtain permits to collect from the wild in the case of rare or declining species. For these reasons, most of the material that is imported and exported for scientific research has no impact whatsoever on the wild populations of the protected species. Scientific research is an activity that serves conservation by generating the scientific knowledge upon which effective conservation and management rest. Indeed, CITES listings and findings on permit applications could not be made without this knowledge."
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