
Paul Fisher
West Palm Beach, FL
APR 9, 2018 — Dear Mr. Solheim,
We the undersigned write today to address grave concerns regarding a recent transfer
of extremely rare birds from the Commonwealth of Dominica to the Federal Republic of Germany under the Convention on International Trade in Endangered Species of Wild Fauna and Flora.
This transfer undermines decades of dedicated conservation work in the region and
exploits a small island nation just as it begins to recover from the most devastating
hurricane in its recorded history. Moving these wild-hatched birds from their home
island to a private facility in Germany is not the first such event--endemic, endangered
parrots have been transferred from other eastern Caribbean islands to the same private
facility. Hence our collective concern that this will not be the last such transfer and our
desire to prevent future actions which will further undermine legitimate efforts to save
these rare species from extinction.
The justification for moving these birds, purported as an emergency action to protect
their species from future hurricanes and volcanoes, is unfounded. In fact, these 12
individual parrots were already safely held in captivity and had survived catastrophic
Hurricane Maria in September. They were being attended to by the CITES Scientific
Authority for Dominica, the Forestry, Wildlife and Parks Division, with support from
IFAW (International Fund for Animal Welfare). Likewise, in Puerto Rico, a similar captive
population of threatened parrots survived the same storm, proving that preparations
made on both islands effectively protect these birds from such threats, however severe.
Since both species involved in this shipment – Amazona imperialis and A. arausiaca -
appear on Appendix I of CITES, a proper international transfer would require the
issuance of both a CITES export permit from Dominica and an import permit from
Germany.
We urge close scrutiny of these documents given that, at the time of the
transfer, Dominica was temporarily under a suspension of “All Trade” by the Convention
(effective 30 January 2018) due to lack of reporting compliance with the
Convention. This fact alone should have prevented the signing of both permits, and
ultimately, the transfer itself.
Additionally, Dominica's CITES Management and Scientific Authorities of record, the
Environmental Coordinating Unit, and Forestry, Wildlife and Parks Division, respectively,
were not contacted about the transfer and neither signed the CITES export permit.
The export permit was signed and executed by an Acting Permanent Secretary. Finally,
the "special conditions" section of the permit references an agreement between ACTP and
the Government of Dominica, but the CITES Management and Scientific Authorities have
no knowledge of any such agreement, and it was not included in the export documentation.
Given the lack of facilities in Dominica to carry out pre-export testing for select
pathogens, we urge additional scrutiny of these aspects of the transfer to determine if
either the European Union’s requirements or Germany’s requirements for quarantine
and testing prior to shipment were adequately met. Naturally, bio-security threats go in
both directions, and untested imported live birds have the potential to introduce
dangerous pathogens to threatened species already held in captive collections in
Europe.
In closing, we thank you for your decades of commitment to ensuring that wildlife trade
does not further threaten the survival of Endangered Species, and respectfully urge
the thorough investigation of all aspects of these recent actions. With appropriate
steps, ideally these detrimental actions can be mitigated and reversed, and
preventative measures can be taken to ensure that no such trafficking of rare species
occurs under the auspices of the Convention.
Signatory Organizations
American Bird Conservancy
Birds Caribbean
City Parrots
Defenders of Wildlife
Durrell Wildlife Conservation Trust
Echo Bonaire
NABU - Nature and Biodiversity Conservation Union
Pro Wildlife e.V.
Rare Species Conservatory Foundation
Species Survival Network
World Parrot Trust
CC:
EU DG Environment
Mr. Gael de Rotalier Team Leader - CITES and EU Wildlife Trade Policy
Ms Emmanuelle Maire - Multilateral environmental Cooperation
Mr. Jorge Rodriguez Romero - Multilateral Environmental Cooperation
Germany - Federal Ministry for the Environment, Nature Conservation, Building and
Nuclear Safety
Ms. Svenja Schulze - Minister
Mr. Gerhard Adams - CITES Management Authority
Mr. Jochen Flasbarth - State Secretary
CITES Secretariat
Mr. John Scanlon - Secretary General
Mr. David Morgan - Chief, Governing Bodies and Meeting Services
Mr. Tom De Meulenaer - Chief, Scientific Services
Mr. Juan Carlos Vasquez - Chief, Legal Affairs & Compliance
CITES Standing Committee
Ms. Carolina Caceres, Chair
Dominica
Mr. Roosevelt Skerrit - Prime Minister
Mr. Minchinton Burton – Director, Forestry, Wildlife and Parks Division
Dr. Reginald Thomas – Acting Permanent Secretary, Ministry of Agriculture and Fisheries
US Fish and Wildlife Service
Dr. Rosemary Gnam – U.S. Scientific Authority
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