In the Office of Endangered U.S. Fish & Wildlife Service United States Department of Interior

Photo: iStockPhoto

A Petition to List 14 Species of Foreign , , & as Threatened or Endangered Under the Act, 16 U.S.C. §§ 1531 et seq.

January 29, 2008

Petitioner: Friends of , 777 Post Road, Suite 205, Darien, Connecticut 06820

Petition Prepared by: Jamie Cotter, Matthew Willson, Kay Bond, Esq., & Lee Hall, Esq. Table of Contents

I. Introduction…………………………………………………………………..1

II. The ESA Listing Process…………………………………………………….2

A. ESA’s Listing Requirements…………………………………………….2 B. Listing Decision Basis………………………………………...... 2

III. BirdLife International, NatureServe, and the IUCN Red List……………3 A. BirdLife International………………………………………...... 3 B. NatureServe………………………………………………………………4 C. IUCN Red List……………………………………………………………4

IV. Species Accounts……………………………………………………………..6 A. Blue-throated macaws ( glaucogularis)…………………………….6 1. Description……………………………………………………...6 2. Distribution and Range……………………………...... 6 3. Life History……………………………………………………..6 4. Abundance and Trend…………………………………………7 5. Threats………………………………………………………….7 B. Blue-headed macaws (Propyrrhura couloni)…………………………....9 1. Description……………………………………………………...9 2. Distribution and Range……………………………...... 9 3. Life History……………………………………………………..9 4. Abundance and Trend………………………………………..10 5. Threats………………………………………………………...10 C. Crimson shining parrots……………………………………………….11 1. Description…………………………………………………….11 2. Distribution and Range……………………………...... 11 3. Life History……………………………………………………11 4. Abundance and Trend………………………………………..11 5. Threats………………………………………………………...12 D. Great green macaws (Ara ambiguus)………………………………….13 1. Description…………………………………………………….13 2. Distribution and Range……………………………...... 13 3. Life History……………………………………………………14 4. Abundance and Trend………………………………………..15 5. Threats………………………………………………………...15 E. Grey-cheeked parakeets (Brotogeris pyrrhoptera)…………………….17 1. Description…………………………………………………….17 2. Distribution and Range……………………………...... 17 3. Life History……………………………………………………17 4. Abundance and Trend………………………………………..17 5. Threats………………………………………………………...18 F. Hyacinth macaws ( hyacinthinus)…………………....19 1. Description…………………………………………………….19 2. Distribution and Range……………………………...... 19 3. Life History……………………………………………………19 4. Abundance and Trend………………………………………..20 5. Threats………………………………………………………...20 G. Military macaws (Ara militaris)………………………………………..22 1. Description…………………………………………………….22 2. Distribution and Range……………………………...... 22 3. Life History……………………………………………………22 4. Abundance and Trend………………………………………..22 5. Threats………………………………………………………...23 H. Philippine cockatoos ( haematuropygia)……………………...24 1. Description…………………………………………………….24 2. Distribution and Range……………………………...... 24 3. Life History……………………………………………………24 4. Abundance and Trend………………………………………..25 5. Threats………………………………………………………...25 I. Red-crowned parrots (Amazona viridigenalis)………………...... 26 1. Description…………………………………………………….26 2. Distribution and Range……………………………...... 26 3. Life History……………………………………………………26 4. Abundance and Trend………………………………………..27 5. Threats………………………………………………………...27 J. Scarlet macaws (Ara macao)…………………………………………...29 1. Description…………………………………………………….29 2. Distribution and Range……………………………...... 29 3. Life History……………………………………………………29 4. Abundance and Trend………………………………………..30 5. Threats………………………………………………………...30 K. Thick-billed parrots (Rhynchopsitta pachyrhyncha)………………….32 1. Description…………………………………………………….32 2. Distribution and Range……………………………...... 32 3. Life History……………………………………………………33 4. Abundance and Trend………………………………………..33 5. Threats………………………………………………………...34 L. White cockatoos (Cacatua alba)………………………………………..35 1. Description…………………………………………………….35 2. Distribution and Range……………………………...... 35 3. Life History……………………………………………………35 4. Abundance and Trend………………………………………..36 5. Threats………………………………………………………...36 M. Yellow-billed (Amazona collaria)………………………………38 1. Description…………………………………………………….38 2. Distribution and Range……………………………...... 38 3. Life History……………………………………………………38 4. Abundance and Trend………………………………………..38 5. Threats………………………………………………………38 N. Yellow-crested cockatoos……………………………………...... 40 1. Description…………………………………………………...40 2. Distribution and Range……………………………...... 40 3. Life History…………………………………………………..40 4. Abundance and Trend………………………………………41 5. Threats……………………………………………………….41

V. Analysis of ESA Listing Factors…………………………………………..43 A. The Present or Threatened Destruction, Modification, or Curtailment of or Range…………………………………………………….43 B. Over-utilization for Commercial and Recreational Purposes—the Pet Trade…………………………………………………………………….43 C. The Inadequacy of Existing Regulatory Mechanisms………………..45 1. CITES…………………………………………………………45 2. Other Inadequate Regulatory Mechanisms………………...47

VI. Conclusion………………………………………………………...... 48 I. Introduction

Friends of Animals hereby petitions the Secretary of the Interior (“Secretary”), acting through the U.S. Fish and Wildlife Service (“Service”), to list, both domestically and internationally, the following species as threatened or endangered under the Endangered Species Act (“ESA”):

Blue-throated macaws (Ara glaucogularis); Blue-headed macaws (Propyrrhura couloni); Crimson shining parrots (Prosopeia splendens); Great green macaws (Ara ambiguous);1 Grey-cheeked parakeets (Brotogeris pyrrhoptera); Hyacinth macaws (Andorhynchus hyacinthinus); Military macaws (Ara militaris); Philippine cockatoos (Cacatua haematuropygia); Red-crowned parrots (Amazona viridigenalis); Scarlet macaws (Ara macao); Thick-billed parrots (Rhynchopsitta pachyrhyncha)2; White cockatoos (Cacatua alba); Yellow-billed parrots (Amazona collaria); and Yellow-crested cockatoos (Cacatua sulphurea);

The caged pet trade threatens the continued survival of these species in the wild. Both legal and illegal pet traders transport from foreign countries into the United States for sale as pets. Currently, the Convention on International Trade in Endangered Species of Wild Flora and Fauna (“CITES”) lists all the bird species subject to this petition (the “petitioned species”) and sets up a system to protect them from trading.3 The Lacey Act and the Wild Bird Conservation Act operate to enforce CITES regulations in the United States.4 Although CITES, the Lacey Act, and the Wild Bird Conservation Act offer some protection to all of the petitioned species, these species continue to be threatened by both legal and illegal trading. Indeed, traders can legally obtain many of the petitioned species with permits.5

Because some legal trading is still allowed and because illegal trafficking is common, the current protection of the petitioned species under CITES and U.S. law is inadequate. In order to protect the petitioned species in the United States, the Secretary should list all of them as either endangered or threatened species within the United States and internationally in their countries of origin. As discussed more fully below, the species qualify for listing under the ESA’s listing factors.6 This petition will explain the ESA listing process, establish that databases maintained by NatureServe, BirdLife International, and the World Conservation Union (“IUCN”) represent the “best scientific and commercial data available,” provide relevant information about each of the petitioned species, and explain why each species should be listed as an endangered or threatened under the ESA.

1 Petitioners request that all of the Great green also be listed domestically and internationally. 2 The Thick-billed parrot is already listed internationally as an endangered species. 45 Fed. Reg. 49844 (July 25, 1980). The U.S. Fish and Wildlife Service admits that the failure to list the Thick-billed parrot as endangered domestically was an “inadvertent oversight.” Id. Therefore, Petitioners request that this species be listed domestically within the United States. 3 See Table B for CITES and other classifications for the species. 4 Lacey Act 16 U.S.C. §§1371 – 3378; Wild Bird Conservation Act 16 U.S.C. §4901. 5 Daniel Hammer, Behind the Bird Trade, Friends of Animals (Summer 2006) available at http://www.friendsofanimals.org/actionline/summer-2006/behind-the-bird-trade.php (last visited Oct. 15, 2007). 6 16 U.S.C. §1533 (2003). 1 II. The ESA Listing Process

Section 4 of the ESA, 16 U.S.C. § 1533, provides a “listing process” to carry out Congress’ intent that the federal government first list and then protect all threatened and endangered species.7 The Supreme Court has stated that the ESA’s structure indicates “beyond doubt” that Congress intended to place the highest priority on protecting endangered species.8 The ESA is the “most comprehensive legislation for the preservation of endangered species ever enacted by any nation.”9 Congress intended to halt and reverse the trend towards species , whatever the cost.10 However, before the ESA can protect a species, that species must first be “listed” under the Act. The ESA protects only those species listed on the official list of threatened and endangered species. Thus, “listing” is a critical first step in ESA’s system of protecting species from extinction. 11

A. ESA’s Listing Requirements

Pursuant to the ESA, the Secretary must determine whether a species is endangered or threatened based on any of the following factors:

(A) the present or threatened destruction, modification, or curtailment of its habit or range; (B) over-utilization for commercial, recreational, scientific, or educational purposes; (C) disease or predation; (D) the inadequacy of existing regulatory mechanisms; or (E) other natural or manmade factors affecting its continued existence.12

If any of these factors are present, the Secretary must list a species as “endangered” or “threatened.” The ESA defines an endangered species as a species that “is in danger of extinction throughout all or a significant portion of its range.”13 A threatened species is a species that is “likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range.”14

B. Listing Decisions Must be Based on “the Best Scientific and Commercial Data Available.”

In evaluating the listing factors, the Secretary must reach his decision “solely on the basis of the best scientific and commercial data available.”15 Further, the Secretary shall give consideration to species that are (i) “designated as requiring protection from unrestricted commerce by any foreign nation, or pursuant to any international agreement; or (ii) identified as in danger of extinction, or likely to become so within the foreseeable future, by any State agency or by any agency of a foreign nation that is responsible for the conservation of fish or wildlife or plants.”16

The ESA specifically states that the Secretary is to make listing determinations based on the best scientific and commercial data available.17 The ESA does not state that any specific amount of data is needed in order to list a species. Therefore, incomplete scientific evidence is not a bar to listing under the ESA. In cases of incomplete data, such as for some of the species in this petition, the Secretary must still rely on the best data available to make listing decisions. This petition provides that data.

7 Tennessee Valley Authority v. Hill, 437 U.S. 153, 180 (1978). 8 Id. at 174 (emphasis added). 9 Tennessee Valley Authority, 437 U.S at 180. 10 Id. 11 16 U.S.C. §1531(a) (2003). 12 16 U.S.C. §1533(a)(1)(A-E) (2003) (emphasis added). 13 16 U.S.C. §1532(6) (2003). 14 16 U.S.C. §1532 (20) (2003). 15 16 U.S.C. §1533(b)(1)(A) (2003). 16 16 U.S.C. § 1533(b)(1)(B)(i) and (ii) (2003). 17 16 U.S.C. §1533 (b)(1)(A) (2003) (emphasis added). 2 Due to the conditions facing these petitioned species, incomplete scientific data is to be expected. 18 The IUCN Red List explains that the absence of high-quality data should not deter attempts at applying listing criteria.19 Although the IUCN Red List and other databases must rely on incomplete information, under the circumstances, this information is still the best scientific and commercial data available, and the Secretary must rely on such information in making listing decisions. In short, lack of perfect data is not an excuse for lack of action.

III. BirdLife International, NatureServe, and the IUCN Red List Constitute the “Best Scientific and Commercial Data Available.”

A. BirdLife International

BirdLife International provides the “best scientific and commercial data available” on the petitioned species.20 Virtually every scientific agency charged with listing imperiled species in the world relies on BirdLife International, and organizations in over one hundred countries partner with BirdLife International.21 Furthermore, BirdLife International is recognized by the Service as a reliable source for information on bird conservation and habitat.22

Unlike other sources of information discussed below, BirdLife International does not categorize or rank species by degree of imperilment. BirdLife International provides information and data so that other organizations can use that information to decide how to rank bird species by degree of threat.23 BirdLife International’s aims are to: (1) prevent the extinction of any bird species; (2) maintain, and where possible improve, the of all bird species; (3) conserve, and where appropriate improve and enlarge, sites and important for birds; (4) help, through birds, to conserve biodiversity and to improve the quality of people's lives; and (5) integrate bird conservation into sustaining people's livelihoods.24 These aims are similar to the aims of the ESA.25

BirdLife International gets its data and information from partnerships with organizations all over the world. BirdLife partners operate in over one hundred countries and collaborate on regional work programs in every continent.26 BirdLife International maintains the World Bird Database with information on approximately 10,000 species of birds, 8,000 Important Bird Areas, and 218 Endemic Bird Areas.27

BirdLife International’s database constitutes the most complete, thorough, and trustworthy source of information about all bird species. The Service should rely on BirdLife International’s databases as the best

18 The two major factors contributing to the lack of concrete information are (1) the length of time since many of the species lived at healthy levels in the wild; and (2) because the species are poached and trapped illegally there are usually not concrete numbers on how many of the species are imported into the United States each year or concrete mortality rates. 19 World Conservation Union (hereinafter “IUCN”), 2001 Categories and Criteria, available at http://www.iucnredlist.org/info/categories_criteria2001 (last visited Oct. 15, 2007). 20 BirdLife International, BirdLife Partners, available at http://www.BirdLife .org/worldwide/national/index.html (last visited Oct. 15, 2007); see also BirdLife International, Cites and the Wild Bird Trade, available at http://www.BirdLife .org/action/change/cites/index.html (last visited January 8, 2008) (Stating that BirdLife International is the official listing authority for birds for the IUCN Red List and contributes to the scientific reviews of proposals to change the listing of bird species on the CITES Appendices. BirdLife International has earned the reputation of being a world leader in identifying global conservation priorities. This activity is essential to ensure that scarce resources are targeted effectively, and has been achieved through BirdLife International’s commitment to painstaking data-gathering and rigorous analysis, benefiting from the practical feedback of field projects in many different countries, and consultation with a worldwide network of experts); BirdLife International, Conservation Science, http://www.BirdLife .org/action/science/index.html (last visited Oct. 15, 2007). 21 Id. 22 United States Fish and Wildlife Service, Birds, available at http://www.fws.gov/birds/ (last visited Oct. 15, 2007). 23 BirdLife International, BirdLife Global Partnership, available at http://www.BirdLife .org/worldwide/global/index.html (last visited Oct. 15, 2007). 24 BirdLife International, Our Vision, available at http://www.BirdLife .org/worldwide/vision/index.html (last visited Oct. 15, 2007). 25 16 U.S.C. §1532 (a) and (b) (2003). 26 BirdLife International, About BirdLife , available at http://www.BirdLife .org/worldwide/index.html (last visited Oct. 15, 2007). 27 BirdLife International, Data Zone, available at http://www.BirdLife .org/datazone/index.html (last visited Oct. 15, 2007). 3 available science. As discussed below both NatureServe and the IUCN Red List rely on information from BirdLife International to rank species by degree of threat. Therefore, the Service should also use their analyses to make its listing decisions about the petitioned species.

B. NatureServe

NatureServe represents another source of the best scientific and commercial data available. NatureServe lists and ranks species by degree of imperilment.28 NatureServe’s listing factors mirror the ESA’s listing factors. NatureServe considers abundance, distribution, population trends, and threats in ranking species.29 These factors are analogous to the ESA’s listing factors described above.30 Similarly, NatureServe’s listing definitions are analogous to the ESA’s listing definitions of endangered and threatened species. NatureServe defines Critically Imperiled (G1) species as species that are at very high risk of extinction due to extreme rarity, very steep declines, or other factors.31 This definition mirrors the ESA’s definition of “endangered” species.32 Similarly, NatureServe defines imperiled species (G1/G2) as species that are at high risk of extinction due to very restricted range, very few populations, steep declines, or other factors.33 This definition is similar to the ESA’s definition of threatened species.34 Therefore, although the terms are different, NatureServe’s definitions are the functional equivalents of the ESA’s definitions.

The Service considers NatureServe an authoritative source of species information. Below every web page for each listed species in the Service’s online Threatened and Endangered Species System, the Service includes the following language:

NatureServe Explorer is a source for authoritative conservation information on more than 50,000 plants, animals, and ecological communities of the U.S and Canada. NatureServe Explorer provides in-depth information on rare and endangered species, but includes common plants and animals too.

Because the Service already considers NatureServe an authoritative source, the Service should rely on NatureServe as representative of the best scientific and commercial data available. For species NatureServe has not considered, and as a third source of the “best scientific and commercial data available,” the Service should rely on the IUCN Red List.

C. IUCN Red List

The IUCN is a global network of over 110 government agencies, 800 non-governmental conservation organizations, and over 10,000 scientists from all over the world. The IUCN supports and develops cutting- edge conservation science and ranks species according to threats on its Red List of Threatened Species.35 Because the IUCN Red List has information on all of the petitioned species and relies on BirdLife International’s data, the Red List represents the best overall, comprehensive database and provides critical information about the species.36 “The IUCN Red List is widely recognized as the most comprehensive, apolitical

28 See Table B for a listing of NatureServe’s classifications of the petitioned species. Because NatureServe does not have information about all of the species, the IUCN Red List is needed to supplement NatureServe’s science and listing data. 29 NatureServe, Global Conservation Status Definitions, available at http://www.natureserve.org/explorer/ranking.htm#globalstatus (last visited Oct 15. 2007). 30 16 U.S.C. 1533(a)(1)(A-E) (2003). 31 NatureServe Conservation Status, Global Conservation Status Definitions, supra note 28. 32 The ESA defines an “endangered” species as one that is “in danger of extinction throughout all or a significant portion of its range.” 16 U.S.C. §1532(6). 33 NatureServe, Global Conservation Status Definitions, supra note 28. 34 The ESA defines a “threatened” species as one that is “likely to become endangered within the foreseeable future throughout all or a significant portion of its range.” 16 U.S.C. §1532 (20). 35 IUCN, An Overview of the IUCN Red List, available at http://www.iucnredlist.org/info/programme (last visited Oct. 15, 2006). 36 See Table B for the Red List listing of the petitioned species. 4 global approach for evaluating the conservation status of plant and species.”37 The goals of the IUCN Red List Program are to (1) identify and document those species most in need of conservation attention if global extinction rates are to be reduced; and (2) provide a global index of the state of degeneration of biodiversity.38

The IUCN Red List works by assigning species to Red List categories based on a set of objective, standard, quantitative criteria.39 As Table C illustrates, the IUCN Red List takes into account essentially all of the relevant information regarding a species in making listing decisions.40 The IUCN Red List represents the most complete source of data for all the petitioned species.

Together, the IUCN Red List, BirdLife International, and NatureServe represent the “best scientific and commercial data available” to the Secretary concerning the petitioned species. Accordingly, rather than restate and duplicate the information already contained in these authoritative databases, Petitioners hereby incorporate all analysis, references, and documentation provide by the IUCN, BirdLife International, and NatureServe on the species at issue into this petition by reference, including all data and analysis underlying the IUCN and NatureServe conservation status classification schemes. This information is abundantly and easily available to the Service on the Internet.

37IUCN, An Overview of the IUCN Red List, supra note 34. 38 Id. 39 IUCN, 2001 Categories and Criteria, Red List of Threatened Species, available at http://www.iucnredlist.org/info/categories_criteria2001 (last visited Oct. 15, 2007). See Table C for a list of the possible listing categories and descriptions of criteria taken into account for each category. 40 See Table C 5 IV. Species Accounts

A. Blue-throated macaws (Ara glaucogularis)

(animal-world.com/.../macaws/bluethroated.php) (http://www.natureserve.org/infonatura/)

1. Description

These large parrots possess long tails, a strong bill, and yellow eyes.41 They have turquoise blue on the upper parts, and bright yellow under parts with blue cheeks and throat patch.42

2. Distribution and Range

Blue-throated macaws inhabit humid lowlands, preferring palm groves, forest “islands” and seasonally inundated .43 The parrots live where phalerat, the palm- they feed upon, are readily available.44 Many people thought this species was extinct outside of captivity until scientists discovered a wild population of Blue-throated macaws in 1992.45 They inhabit almost 9,000 kilometers of northern and are concentrated east of the upper río Mamoré, Beni.46

3. Life History

The breeding season of Blue-throated macaws lasts from November to March.47 During this time, Blue- throated macaws construct nests within cavities of large trees, preferring palm trees, and raise their chicks there.48 Suitable nesting sites are rare. These birds require large pre-existing cavities in old growth trees--trees that may be hundreds of years old.49 Without a proper nesting site, Blue-throated macaws will not mate.50

41 ARKive.org, Ara glaucogularis, available at http://www.arkive.org/species/GES/birds/Ara_glaucogularis/more_info.html (last visited Sept. 19, 2007). 42 Id. 43 Id., see also IUCN, Ara glaucogularis, available at http://www.iucnredlist.org/search/details.php/1968/all (last visited Sept. 19, 2007). 44 ARKive.org, Ara glaucogularis, supra note 40. 45 IUCN, Ara glaucogularis, supra note 42. 46 Id. 47 Id., see also ARKive.org, Ara glaucogularis, supra note 40. 48 ARKive.org, Ara glaucogularis, supra note 40; see also IUCN, Ara glaucogularis, supra note 42. 49 Donald Brightsmith, The Tambopata Macaw Project, Duke University Department of Biology, available at http://www.duke.edu/~djb4/ (last visited Oct. 10, 2007). 50 Id. 6 These macaws have an extremely low breeding rate due to several factors.51 First, suitable nesting trees occur sporadically over a large area.52 Second, only about 60% of the nests actually fledge, due to loss to predation and disease.53 Third, Blue-throated macaws only fledge one chick, even if more survive, leaving the others to starve to death.54 Thus, a wild population of 200 birds or so may produce less than ten young per year.55 Fledging chicks in captivity has been somewhat successful, but hand-raised macaws have no fear of humans and once reintroduced to the wild willingly approach them looking for food.56 This acclimation to humans makes these macaws prone to easy capture.57

4. Abundance and Trend

In the 1980s, traders exported at least 1,200 wild Blue-throated macaws from Bolivia for the international pet bird trade.58 According to the IUCN Red List, there are about 120 birds left in an 8,600- kilometer range, with the most recent population count finding 36 Blue-throated macaws.59 Species experts believe that there are now more Blue-throated macaws in captivity than in the wild.60

5. Threats

Blue-throated macaws are protected by law in their natural habitat in Bolivia61 and the birds are listed on Appendix I of CITES.62 The two greatest threats to the Blue-throated macaws continued survival are the pet trade and habitat loss. Currently there is very little scientific research on the ecology of Blue-throated macaws.63 Scientists do know that the species depends on the A. phalerta fruit and the forest islands where these trees grow.64 The clearing of forestland for agriculture, fuel, and cattle grazing has reduced the area of suitable nesting sites.65 Likewise, suitable macaw habitat is decreasing because of land use practices in the region, which include burning under-story palms where the macaws feed and nest.66 Large-scale ranching in the habitat means grazing cattle often trample young A. phalerta palms impeding replacement by new trees.67

Species experts have said that the bird trade in Blue-throated macaws is “a serious issue warranting immediate attention.”68 Experts have suggested, based on discrepancies between CITES data and quarantine data, that traders imported 1,200 of these macaws into the United States since 1981.69 Even though some legal protection for this bird exists, the illegal trade in captured Blue-throated macaws for pets continues.70 Today all suitable habitat is on privately held ranches where illegal capture interdiction can be difficult.71 The Bolivian

51 Id. 52 Id. 53 Id. 54 Id. 55 Id. 56 Id. 57 Id. 58 IUCN, Ara glaucogularis, supra note 42. 59 Brightsmith, The Tambopata Macaw Project, supra note 48. 60 Id. 61 Id. 62 IUCN, Ara glaucogularis, supra note 42; see also ARKive.org, Ara glaucogularis, supra note 40. 63 ARKive.org, Ara glaucogularis, supra note 40. 64 A. Hesse and G. Duffield, The Status and Conservation of the Blue-Throated Macaw Ara glaucogularis, 10 BIRD CONSERVATION INT’L 225-275 (2000). 65 Id. 66 ARKive.org, Ara glaucogularis, supra note 40. 67 A. Hesse and G. Duffield, The Status and Conservation of the Blue-Throated Macaw Ara glaucogularis, supra note 63. 68 Id. 69 Id. 70 ARKive.org, Ara glaucogularis, supra note 40. 71 Id. 7 government has agreements with some landowners in an effort to deter potential trappers, and others have suggested using fulltime guards to stop trapping.72

Blue-throated macaws are trapped in various ways. Snares may be set on perches, ladders are used to raid nests, fires are set as the bases of trees to flush out the birds and adults may be shot in the wing while in flight to allow capture.73 Chicks are the most prized catch, as they do better in captivity than wild adults.74 Often, illegal collectors will cut down a tree to reach a nest when they cannot easily access it.75 The resulting fall kills 60% of the chicks gathered this way.76 It also removes an already rare nesting site from future use by the species.77

The illegal pet trade has decimated the population of wild Blue-throated macaws.78 Past captures for the cage-bird market reduced the population to the point that scientists thought, until the early 1990s, Blue-throated macaws were extinct in the wild.79 Continued illegal capture on the private lands where the birds live threatens the few Blue-throated macaws left.80 The pressure placed on the species by the pet trade has left the wild populations fragmented and vulnerable.81 Lastly, the very rarity of Blue-throated macaws make these birds prized among the pet-trade and collectors, further pressuring the remaining wild birds.82

72 Id., see also IUCN, Ara glaucogularis, supra note 42. 73 Brightsimth, The Tambopata Macaw Project, supra note 48. 74 Id. 75 Id. 76 Id. 77 Id. 78 IUCN, Ara glaucogularis, supra note 42, see also ARKive.org, Ara glaucogularis, supra note 40. 79 IUCN, Ara glaucogularis, supra note 42. 80 ARKive.org, Ara glaucogularis, supra note 40. 81 Id. 82 Id. 8 B. Blue-headed macaws (Propyrrhura couloni)

(http://www.toolady.com/articles/bird27.jpg) (http://www.natureserve.org/infonatura/)

1. Description

These parrots, known for their vivid blue-green plumage, have bright blue heads and green .83 Dark blue foreheads, throats, and cheeks blend into the lighter blue necks.84 The edge of the wings can be bright blue while the lower parts of the tails are maroon and the lower body is yellowish-green.85 These birds have black bills tipped in white and pink legs and feet.86 Blue-headed macaws are very vocal both in flight and when perched.87 These birds are most often located by researchers and trappers based on their loud calls.88

2. Distribution and Range

Blue-headed macaws prefer humid habitats. Often these parrots live along rivers, at the edges of lowland evergreen forest and in breaks in the forest canopy.89 These birds live in westernmost , eastern , and northwestern Bolivia in a global range of 609,494 square kilometers.90 Blue-headed macaws prefer plains and lowlands to a height of 1,550 meters.91

3. Life History

While the diet of these macaws is unidentified, observers have seen these birds ingesting soil at “clay licks,” a behavior in birds that is largely unknown. Blue-headed macaws have their young in April, and their breeding season ranges from October until that time.92 The species has a very low reproductive rate.93 The birds lay approximately four eggs, incubating in about a month, and then the chicks fledge three or so months later.94 Blue-headed macaws often travel in pairs or threes outside of the breeding season.95

83 ARKive.org, Propyrrhura couloni, available at http://www.arkive.org/species/GES/birds/Primolius_couloni/more_info.html#reference_5 (last visited Sept. 19, 2007). 84 Id. 85 Id. 86 Id. 87 J. Tobias and D. Brightsmith, Distribution, ecology and conservation status of the Blue-headed Macaw couloni, 139 BIOLOGICAL CONSERVATION 126-138 (2007). 88 Id. 89 IUCN, Propyrrhura couloni, available at http://www.iucnredlist.org/search/details.php/48029/all (last visited Sept. 30, 2007). 90 J. Tobias and D. Brightsmith, supra note 86. 91 Id. 92 Id. 93 IUCN, Propyrrhura couloni, supra note 88. 94 ARKIve.org, Propyrrhura couloni, supra note 82. 95 Id. 9 4. Abundance and Trend

Estimates of the numbers of wild Blue-headed macaws vary. Despite several studies, no Blue-headed macaws have been seen in Bolivia for the eight years leading up to a 2002 study.96 Although experts have suggested that between 545 and 46,000 mature adults may presently exist,97 scientists can only account for 100- 200 birds in the wild for the 2005 IUCN Red List assessment.

5. Threats

Blue-headed macaws are listed on CITES Appendix I and protected in Brazil but not in the neighboring countries of Peru or Bolivia.98 The largest single threat to the continued existence of Blue-headed macaws is the pet trade99 and the birds rank as Endangered on the 2006 IUCN Red List due to pet trade exploitation. Markets in Brazil regularly sell these macaws as caged pets.100 Since 1995, the international trade has increased for both legally and illegally obtained birds.101 One hundred and fifty legally obtained and fifty illegally obtained Blue- headed macaws were known to be traded between 1993 and 2000.102 Due to their rarity, Blue-headed macaws cost as much as $12,500 per bird.103 The loud distinctive calls travel some distance, and their regular use of the same clay licks each year, makes these birds easy to trap.104

Law enforcement officers has confiscated illegally obtained Blue-headed macaws in several nations; six were taken in the U.K. in 1998, thirty were found in Peru, an estimated fifty in former Soviet Union countries in the 1990s, and another thirty in Germany in 2001.105 These macaws are regularly found in Brazilian bird markets and traders claim to be able to obtain CITES export permits and documentation.106 In Bolivian markets, foreign traders purchased up to thirty Blue-headed macaws in 1995.107 One expert believes that due to rarity Blue-headed macaws are the most sought after parrots among bird collectors today.108

Rarity of the birds coupled with a low reproductive rate means pressure on this species is mounting as these macaws are becoming increasingly popular with pet trade collectors. Although habitat loss is not currently a significant threat, continued logging of the Bolivian forest may put added pressure on the remaining wild population of these rare macaws.109

96 IUCN, Propyrrhura couloni, supra note 88. 97 J. Tobias and D. Brightsmith, supra note 86. 98 CITES, Transfer of Blue-headed Macaw Ara couloni from the Appendix II to Appendix I, Ref. CoP 12 Prop 18, ICUN, available at http://intranet.iucn.org/webfiles/doc/SSC/CoP12/Analyses/1218.pdf (last visited Oct. 10, 2007). 99 Id., see also ARKIve.org, Propyrrhura couloni, supra note 82. 100 IUCN, Propyrrhura couloni, supra note 88. 101 ARKIve.org, Propyrrhura couloni, supra note 82. 102 Tobias and Brightsmith, supra note 86. 103 Id. 104 Id. 105 Id. 106 Germany, Transfer of Blue-headed Macaw Ara couloni from the Appendix II to Appendix I, supra note 97. 107 Id. 108 Id. 109 Id. 10 C. Crimson shining parrots (Prosopeia splendens)

(http://www.BirdLife.info/wbdbweb/images/speciesmap/2000-1448.gif)

1. Description

These parrots sport a scarlet-crimson head, neck, and under parts with a narrow blue neck collar.110 They have bright green wings and a back with greenish-blue flight and long tail feathers.111 These birds make several different squawks, rattles, and screeches and reach approximately 45 centimeters in length.112

2. Distribution and Range

Crimson shining parrots live in forests and agricultural lands as well as around human habitation on the islands of Fiji.113

3. Life History

Scientists know very little about the parrots’ breeding habits except that they nest in holes.114 The primary forage for these birds is and fruit found in the forest canopy.115

4. Abundance and Trend

Crimson shining parrots are endemic to Fiji, occurring in the wild only on the islands of Kadavu and Ono.116 Kadavu has a forest area of 225 square kilometers of suitable habitat for the parrot.117 The current population estimate is around 6,000 wild birds.118

110 BirdLife International, Prosopeia splendens, available at http://www.BirdLife .org/datazone/search/species_search.html?action=SpcHTMDetails.asp&sid=1448&m=0 (last visited Sept. 19, 2007). 111 Id. 112 Id. 113 IUCN, Prosopeia splendens, available at http://www.iucnredlist.org/search/details.php/18370/all (last visited Sept. 19, 2007). 114 BirdLife International, Prosopeia splendens, supra note 109. 115 Id. 116 World Conservation Union, Prosopeia splendens, supra note 112. 117 Id. 118 Id. 11 5. Threats

The greatest threats to Crimson shining parrots are the pet trade and . The IUCN Red List names this species as “vulnerable” due to its small population and limited habitat.119 Declining mangrove forest area in the near future will put habitat pressure on the parrots.120 There is also international illegal traffic in Crimson shining parrots due to demand from the pet trade.121

119 World Conservation Union, Prosopeia splendens, supra note 112. 120 Id. 121 Id. 12 D. Great green macaws (Ara ambiguus)

(www.arkive.org/species/GES/birds/Ara_ambigua/GES007689.html) (http://www.natureserve.org/infonatura/)

1. Description

These very large parrots can reach up to 90 cm.122 making them the second largest parrots in the Americas.123 The upper wing, head, and back are all olive green while the wing tips and tail ends are a pale blue.124 The main parts of the tail are bright orange and the facile lines tend to be bright red.125 Large, powerful black bills dominate the birds’ faces.126 Great green macaws make loud squawks and are constantly making noises in flight or when perched.127 There are two subspecies: the nominate race, with habitat from to , and the guayaquilensis race, with habitat only in .128

2. Distribution and Range

Once widespread throughout Central and , Great green macaws are now only found in a handful of countries.129 Today pockets of these parrots can be found in Colombia, , Ecuador, Honduras, , and .130 In Panama, these birds can be found on the Caribbean Slope and along the border with Columbia.131 In Columbia itself, Great green macaws have been spotted in the north of the country

122 BirdLife International, Ara ambiguus, available at http://www.BirdLife .org/datazone/species/index.html?action=SpcHTMDetails.asp&sid=1550&m=0 (last visited Jan. 8, 2008). 123 Charles Bergman, Collared greens – green macaws of Costa Rica, American Museum Natural History, (2000) available at http://findarticles.com/p/articles/mi_m1134/is_3_109/ai_61524421(last visited Jan. 08, 2008). 124 ARKIve.org, Ara ambigua, available at http://www.arkive.org/species/GES/birds/Ara_ambigua/ (last visited Jan. 8, 2008). 125 BirdLife International, Ara ambiguus, supra note 122. 126 Id. 127 Id. 128 Id. 129 ARKIve.org, Ara ambigua, supra note 124. 130 Id. 131 BirdLife International, Ara ambiguus, supra note 122. 13 and in the West region. 132 These birds are generally uncommon throughout Honduras, and in Nicaragua, they are found only in the Bosawas Reserve.133 Estimates for the number of Great green macaws in Ecuador are less than 100 individuals.134 In Costa Rica, only 25-35 pairs of Great green macaws are left.135

Great green macaws inhabit humid lowlands and foothills mainly below 600 meters, but the birds have been observed as high as 1,500 meters.136 They prefer deciduous forest but also live in edge habitats and are known to cross open areas to reach other feeding grounds.137 In Costa Rica, Great green macaws have been observed following fruiting patterns of the trees on which they feed.138 The Costa Rican population while small, is the most heavily studied, and is located in the Northern zone of the country in the area between the San Carlos, San Juan, and Saraqiqui Rivers.139 BirdLife International estimates that the separate populations of Great green macaws have an overall range for breeding and feeding of 100,000 km2.

3. Life History

Great green macaws are often seen in small family groups of 5-6 individuals, although in the past they had been observed in flocks as large as 50.140 These birds are slow breeding, taking five to six years to reach sexual maturity and they do not nest every year.141 The population in Ecuador nests in June through November in the cavities of dead trees.142 The Costa Rican populations return to their nesting sites in November and December to form breeding pairs.143 In January and February, the eggs are laid and the incubation period of 30 days begins.144 Upon hatching, the youngsters will stay in the nest for about 60 days where they are tended to by the parents.145 Once fledged the young do not venture far from the nest, still being reliant on their parents for food and flight training.146 By mid summer, the Costa Rican young start to fly on their own and begin the annual migration in their foraging areas as food availability starts to change.147 With an average of 19 nests found per year, it is estimated that only 35 breeding pairs exist in the 1,200 km2 Costa Rican breeding range.

The Costa Rican population is highly dependent on one type of food and nesting tree, Diptreyx panamensis148, commonly known as alemendro, a hardwood tree that was once unpopular with loggers due to its toughness to cut with a handsaw, but has now become a prized wood that is actively sought due to its superior strength. The Great green macaws use the alemendro tree as their primary nesting spot in 88% of the recorded cases.149 These birds are also highly dependent on the trees’ as a primary food source.150 The fruits, an almond type, occur in unison with the Great green macaws’ breeding season, first sprouting in October and lasting until April.151 Only after the Diptreyx panamensis are gone do Great green macaws start to travel looking

132 Id. 133 Id. 134 Id. 135 Id. 136 IUCN, Ara ambiguus, available at http://www.iucnredlist.org/search/details.php/40207/summ (last visited Jan. 8, 2008). 137 Id 138 Id. 139 Great Green Macaw Project, The Great Green Macaw en route to extinction, available at http://www.lapaverde.or.cr/lapa/index_eng_lapa.htm (last visited Jan. 8, 2008). 140 ARKIve.org, Ara ambigua, supra note 124. 141 Bergman, Collared greens – green macaws of Costa Rica, supra note 123. 142 BirdLife International, Ara ambiguus, supra note 122. 143 Great Green Macaw Project, The Great Green Macaw en Route to Extinction, available at http://www.lapaverde.or.cr/lapa/index_eng_lapa.htm (last visited Jan. 8, 2008). 144 Id. 145 Id. 146 Id. 147 Id. 148 Bergman, Collared greens – green macaws of Costa Rica, supra note 123. 149 United Kingdom Parrot Society, The Great-Green Macaw, available at www.theparrotsocietyuk.org (last visited Jan. 8, 2008). 150 Bergman, Collared greens – green macaws of Costa Rica, supra note 123. 151 Id. 14 for other food supplies, predominantly the Sacoglottis trichogyna or Titor tree.152 Because of their dependence on the alemendro trees, Great green macaws’ survival is closely tied to the continuing availability of the tree for nesting and food.153

4. Abundance and Trend

Only 1,000-2,499 Great green macaws are left in the wild.154 The Great Green Macaw Project estimates there is currently no subpopulation of more that 250 birds in , and a decline of 50% over the next three generations is projected.155 The population in Ecuador is believed to be between 60-90 individuals, while in Costa Rica there are only 25-35 breeding pairs left.156 Species experts say that a population of these macaws must consist of at least a bare minimum of 50 breeding pairs to maintain itself, even for the short term.157

5. Threats

Currently Great green macaws are listed on CITES Appendices I and II, as well as listed as Endangered on the IUCN Red List due to habitat loss and persecution from the pet trade.158 The largest single factor affecting these macaws is the loss of habitat throughout their range.159 Forests in range of Great green macaws are being lost at an alarming rate. Habitat is lost to agriculture as trees are cleared for plantations, for cattle ranching and for logging.160 The current range in Costa Rica is about 1,200 km2 and includes the largest number of alemendro trees,161 the fruit of which these macaws depend on as a primary food source, and in whose trunks they primarily nest. Recently these trees have become prized for their wood, and are increasingly sought after by legal and illegal loggers. Today in Costa Rica, less than 30% of Great green macaws’ historic habitat exists, placing more pressure on these birds to find enough food and suitable nesting sites in what little remains, with active nests found in only about 5% of their historic range. A 1994 study in Costa Rica found just 60 nesting sites, and ten years later 1/6 of those nest trees had been cut for logging.162

The pet trade is other major factor influencing Great green macaws’ rapid decline. In Nicaragua, all sorts of endangered parrots can be bought in the major cities.163 Great green macaw nestlings can be purchased for $200-400 each; these same birds fetch around $2,000 each in the US as pets.164 A 2004 Nicaraguan study showed the numbers of wild parrots in the country had dropped 69% since the last study in 1999.165 Nicaragua’s Environment Minster has said they have been frustrated in controlling the pet trade problem due to economic pressures and a lack of resources.166

A recent BBC News article discusses the extent of the pet trade problem in Nicaragua, especially for Great green macaws as their only known population is in the protected Bosawas Reserve. A street vendor selling wild parrots approached an international reporter on assignment in Managua.167 When the reporter said

152 Id. 153 Id. 154 BirdLife International, Ara ambiguus, supra note 122. 155 United Kingdom Parrot Society, The Great-Green Macaw, supra note 149. 156 IUCN, Ara ambiguus, supra note 136. 157 Great Green Macaw Project, The Great Green Macaw en route to extinction, supra note 139. 158 BirdLife International, Ara ambiguus, supra note 122. 159 ARKIve.org, Ara ambigua, supra note 124 160 Id. 161 United Kingdom Parrot Society, The Great-Green Macaw, supra note 149. 162 Bergman, Collared greens – green macaws of Costa Rica, supra note 123. 163 BirdLife International, Ara ambiguus, supra note 122. 164 Id. 165 Id 166 Id 167 Duncan Kennedy, Endangered birds on offer in Nicaragua, BBC NEWS, (2007) available at http://news.bbc.co.uk/2/hi/americas/6460185.stm (last visited Jan. 8, 2008). 15 he was not interested, the poacher replied he had “others, much better ones.”168 The reporter seeing a possible story, agreed and the poacher jumped into his car with three of his birds in a plastic bag.169 Together they drove forty miles outside of the capital until they reached the edge of a (and by then one of the parrots in the bag had already died).170 Here the poacher showed him two large macaws (one would later be identified as a Great Green).171 The haggling began at $1,000 US, but ended with the agreed price at $400.172 Later when the reporter asked the Nicaraguan government how such a thing could continue to happen when Great green macaws are not only listed on CITES but protected in Nicaragua, the response was that it is almost impossible to stop the poachers.173 The people taking these birds are poor and the street value of the easily captured birds is just too great to ignore. They have even taken to painting other parrots to look like the more lucrative species just to supply the pet trade market.174 The government minister said they have just 20 wardens patrolling a 13,000 sq kilometer area popular with wild parrot poachers.175

This is just one example of the reach and demand in the wild parrot pet trade. It is likely not limited to Nicaragua. Great green macaws are prized pets, and can demand a lot of money in the US. Thus, it is likely the scene in Nicaragua is repeated throughout its range. So long as demand remains for these parrots as pets in the US, people will continue to poach them wherever they can still be found.

168 Id. 169 Id. 170 Id. 171 Id. 172 Id. 173 Id. 174 Id. 175 Id. 16 E. Grey-cheeked parakeets (Brotogeris pyrrhoptera)

(www.birdchannel.com/bird-species/g_landing.aspx) (http://www.natureserve.org/infonatura/)

1. Description

These small parakeets, 20 centimeters in length, have a pale blue head, orange under parts, bluish body, a large bill, and grey cheeks from which it takes its common name.176 In flight, Grey-cheeked parakeets produce a shrill sound; while perched, the call is more muted.177

2. Distribution and Range

These birds live in southwest Ecuador and extreme northwest Peru. They commonly live in coastal areas along the border between Ecuador and Peru.178 Grey-cheeked parrots prefer humid evergreen forest, but also inhabit open scrubland and agricultural areas.179

3. Life History

Grey-cheeked parakeets live in pairs or with a small flock.180 Their diet consists of seeds, flowers, and fruit with the Cieba fruit being a favorite.181 These parakeets also eat and corn in agricultural areas.182Breeding season lasts from February to August with most activity during the rainy season from January to March.183

4. Abundance and Trend

The population of Grey-cheeked parakeets decreased rapidly in the 1980s when traders began heavily exporting these birds for the pet trade.184 CITES nations imported an estimated 59,000 birds in just five years during that decade.185 CITES lists the U.S. as the largest single importer with more than 83,000 Grey-cheeked

176 BirdLife International, Brotogeris pyrrhoptera, available at http://www.BirdLife .org/datazone/search/species_search.html?action=SpcHTMDetails.asp&sid=1624&m=0 (last visited Jan. 8, 2007). 177 Id. 178 Id. 179 Id. 180 Id. 181 Id. 182 Id. 183 Id. 184 Id. 185 Id. 17 parakeets brought here between 1980 and 1989 from either Ecuador or Peru.186 The most recent wild population estimate comes from the mid 1990s at 15,000 Grey-cheeked parakeets left in the wild.187

5. Threats

Grey-cheeked parakeets are listed on CITES Appendix II and are ranked as endangered on the IUCN Red List due to rapid population decreases from pet trade captures.188 Both Ecuador and Peru have regulations protecting these birds but trapping for the pet trade remains the greatest threat to their survival.189 The numbers imported by CITES nations is only the tip of the iceberg; the international trade is much greater.190 Habitat destruction also threatens the continued existence of Grey-cheeked parakeets. Logging, agricultural land clearing and grazing by cattle is decreasing available nesting and foraging lands.191

186 Convention on International Trade in Endangered Species of Wild Flora and Fauna (“CITES”), available at www..org (last visited, Oct. 15, 2007). 187 Id. 188 BirdLife International, Brotogeris pyrrhoptera, supra note 176. 189 Id. 190 Id. 191 Id. 18 F. Hyacinth macaws (Anodorhynchus hyacinthinus)

(http://www.ejphoto.com/hyacinth_macaw_page.htm) (http://www.natureserve.org/infonatura/)

1. Description

At 100 centimeters in length, Hyacinth macaws are the largest parrots in the world.192 These striking birds have a yellow circle around the eye and bright blue body and flight feathers.193 These parrots have a small yellow patch just above their huge bills and long tails.194 Like most parrots, they use their strong legs along with their bill to hang sideways or upside-down when feeding.195 Hyacinth macaws often call in pairs with a loud high-pitched screeching sound.196

2. Distribution and Range

These parrots live primarily in Brazil with some appearing in Bolivia and .197 They prefer the open savanna on the edge of tropical forests and palm forests.198 Hyacinth macaws have breeding and forage ranges of approximately 539,000 square kilometers. Their primary diet consists of fruit and nuts from a few endemic palm species found within that range.199

3. Life History

Hyacinth macaws breed between July and December, creating nests in tree cavities and on cliff sides.200 They breed in monogamous pairs staying together for life.201 Only 15-30% of all adult Hyacinth macaws will breed in any year. The females usually lay two eggs, but only one chick eventually fledges.202 Incubation lasts

192 ARKive.org, Anodorhynchus hyacinthinus, available at http://www.arkive.org/species/GES/birds/Anodorhynchus _hyacinthinus/more_info.html (last visited Sept. 19, 2007). 193 Id.; see also BirdLife International, Anodorhynchus hyacinthinus, available at http://www.BirdLife .org/datazone/search/species_search.html?action=SpcHTMDetails.asp&sid=1543&m=0 (last visited Sept. 19, 2007). 194 Id. 195 E. Hagan, Anodorhynchus hyacinthinus, , available at http://animaldiversity.ummz.umich.edu/site/accounts/information/Anodorhynchus_hyacinthinus.html (last visited Oct. 15, 2007). 196 BirdLife International, Anodorhynchus hyacinthinus, supra note 193. 197 ARKive.org, Anodorhynchus hyacinthinus, supra note 192. 198 IUCN, Anodorhynchus hyacinthinus, available at http://www.iucnredlist.org/search/details.php/1314/all (last visited Jan. 8, 2008). 199 BirdLife International, Anodorhynchus hyacinthinus, supra note 193; see also ARKive.org, Anodorhynchus hyacinthinus, supra note 192. 200 BirdLife International, Anodorhynchus hyacinthinus, supra note 193; see also ARKive.org, Anodorhynchus hyacinthinus, supra note 192. 201 Hagan, Anodorhynchus hyacinthinus, supra note 195. 202 Id. 19 for a month. Male Hyacinth macaws tend to the females’ needs while they care for the eggs.203 Their low reproductive rate means 100 pairs may have twenty-five or less offspring a year.204 After three months or so, the young chicks fledge but remain dependent on their mothers for at least six months, up to a year.205

Hyacinth macaws are extremely social birds.206 They carry out courting and bonding activities and while often seen in pairs they will flock with other Hyacinth macaws in groups up to eight.207 In the mornings to mid-afternoon, these flocks will travel together between feeding grounds before returning to their roosts at sunset.208 These flights can cover long distances and are usually quite high.209 These macaws feed primarily on eight species of palm nuts, with the variety depending on what species of palm live in that habitat.210 These nuts have hard shells, which Hyacinth macaws crack open with their powerful .211 Palm feeding serves an important ecosystem role as it disperses the seeds over large areas of habitat.212

4. Abundance and Trend

In the mid 1800s, Hyacinth macaws were “very abundant.”213 By 1910, scientists classified them as only “abundant” and in 1956, only small flocks of about ten birds were seen.214 By the 1980s, experts considered these macaws “truly rare.”215 The estimated population range for Hyacinth macaws is between 2,500 and 10,000 left in the wild.216

5. Threats

Loss to the pet bird trade is the greatest threat to these macaws. In fact, species experts widely agree that this is the primary reason for the birds’ rapid decline.217 The species is currently listed under CITES Appendix I and classified as endangered on the IUCN Red List as well as protected from capture and export in all countries of origin.218 Despite these protections, massive illegal trapping for the pet trade continues.219 More than 10,000 captured wild birds were sold as pets in the 1980s.220 Although no data exists on the exact numbers taken since then, it is likely illegal captures have continued, as demand for these birds as pets has not waned. Experts believe that, given their low reproductive rate, Hyacinth macaws cannot further endure the pet trade.221 In the late 1980s, a trapper could receive $40-$60 per bird, then intermediaries and wild bird traders would resell them for hundreds more, with these macaws getting progressively more expensive until they ultimately became someone’s pet.222 Trapping is relatively easy given the large size and very vocal nature of

203 ARKive.org, Anodorhynchus hyacinthinus, supra note 192. 204 Hagan, Anodorhynchus hyacinthinus, supra note 195. 205 Id. 206 Id. 207 Id. 208 Id. 209 N.J. Collar, Entry On the Hyacinth Macaw, Threatened Birds of North America, available at http://www.bluemacaws.org/hywild10.htm (last visited Oct. 10, 2007). 210 Id. 211 Id. 212 Id. 213 N.J. Collar, Entry On the Hyacinth Macaw, supra note 209. 214 Id. 215 Id. 216 BirdLife International, Anodorhynchus hyacinthinus, supra note 193. 217 Collar, Entry On the Hyacinth Macaw, supra note 209. 218 IUCN, Anodorhynchus hyacinthinus, available at http://www.iucnredlist.org/search/details.php/1314/all (last visited Jan. 2, 2008); see also ARKive.org, Anodorhynchus hyacinthinus, supra note 192. 219 IUCN, Anodorhynchus hyacinthinus, supra note 218. 220 Id.; see also ARKive.org, Anodorhynchus hyacinthinus, supra note 192. 221 Charles Munn, Report on the Hyacinth Macaw, AUDUBON WILDLIFE REPORT 405-419 (1989/90) available at http://www.bluemacaws.org/hywild15.htm (last visited Oct. 10, 2007). 222 Id. 20 these birds.223 Because Hyacinth macaws only eat certain palm fruits, it is easy to predict their location.224 In sum, these macaws an easy target for trappers.

Chicks are the preferred targets of trappers as they make better pets, but the mortality rate is extremely high. One international bird trader claimed a 99% mortality rate on a shipment of 300 young.225 Interviews with other trappers report individuals taking between 200-1000 Hyacinth macaws each in a year to feed the demand for these coveted pets.226

The United States is a large consumer of wild Hyacinth macaws for pets. Between 1975 and 1982, 1,113 of these birds were recorded as having entered the United States, the vast majority coming in from Bolivia.227 Between 1981 and 1984 CITES declarations reported 702 Hyacinth macaws entered the United States, while quarantine sources for the same period show that actually 1,382 birds came here.228 Thus, CITES declarations are likely far lower than the actual number imported. This of course does not include illegal birds brought into this country, as those numbers are extremely hard to gauge. Some experts believe illegal trade could be three times that of CITES reported imports.229 It appears that CITES may even have increased the number of macaws taken in the wild, because of enhanced knowledge of their rarity.230 Hyacinth macaws were placed on Appendix I in 1987, and by a year later over 700 birds where know to have been trapped and traded illegally.231 The international market for these birds is probably large because these birds are the preferred pet macaws.

Hyacinth macaws also face pressure from habitat loss to cattle ranching and hydroelectric development.232 Furthermore, the large size of these macaws makes them a target of local hunting for food and feathers.233

223 Collar, Entry On the Hyacinth Macaw, supra note 209. 224 Id. 225 Id. 226 Id. 227 Id. 228 Id. 229 Munn, Report on the Hyacinth Macaw, supra note 221. 230 Id. 231 Id. 232 Id. 233 BirdLife International, Anodorhynchus hyacinthinus, supra note 193. 21 G. Military macaws (Ara militaris)

(www.riorvpark.com/Tamaulipas%20_August_2006.htm) (http://www.natureserve.org/infonatura/)

1. Description

These large macaws can reach 70 centimeters in length with a wingspan of up to 43 inches.234 Military macaws have blue flight feathers with an overall lime green coloring.235 A red forehead, black , and long red and blue tail round out these colorful birds.236 These macaws make shrieks and a distinctive “c-r-a-a-a-k” call.237

2. Distribution and Range

Military macaws prefer humid lowland forest as well as adjacent clearings, canyons, forest, and semi-arid woodland.238 These macaws prefer altitudes of 500-1,500 meters.239 Their range covers a massive area, but suitable habitat is highly fragmented between several countries.240 These birds live in Columbia, , Ecuador, Peru, Bolivia, and .241 Although Military macaws once inhabited , people have not found them in the wild there since 1991.242

3. Life History

Military macaws are communal nesters favoring cliff faces or large trees for roosts.243

4. Abundance and Trend

Population estimates range between 10,000 and 20,000 individuals left in the wild.244

234 BirdLife International, Ara militaris, available at http://www.BirdLife .org/datazone/search/species_search.html?action=SpcHTMDetails.asp&sid=1549&m=0 (last visited Sept. 19, 2007). 235 Id. 236 Id. 237 Id. 238 Id. 239 Id. 240 Id. 241 Id. 242 Id. 243 IUCN, Ara militaris, available at http://www.iucnredlist.org/search/details.php/1972/all (last visited Jan. 8, 2008)., see also BirdLife International, Ara militaris, supra note 234. 244 BirdLife International, Ara militaris, supra note 234. 22 5. Threats

The species is listed on the IUCN Red List as vulnerable and on CITES Appendix I, and is protected in Venezuela.245 The pet trade and habitat loss are the most significant threats to this species. Military macaws are commonly found as caged pets in the United States246 They can be purchased through pet stores, classified ads and online.247 The price for an individual ranges between $800-$1200.248 These macaws live in many reserves and protected areas in the countries they inhabit, but these areas are not well policed, and trapping for the pet trade continues.

245 IUCN, Ara militaris, supra note 243. 246 Vanessa Girton, Military Macaw, BIRD TIMES, available at http://www.petpublishing.com/birdtimes/breeds/militarymac.shtml (last visited Oct. 10, 2007). 247 Id. 248 Id. 23 H. Philippine cockatoos (Cacatua haematuropygia)

(www.pcsd.ph/.../fauna/philippinecockatoo.htm) (http://www.rdb.or.id/detailbird.php?id=45)

1. Description

Adult Philippine cockatoos can reach a length of 31 centimeters.249 They weigh in at around 0.29 kilograms.250 These small cockatoos have a short erect topping the head, white body feathers, and deep yellow below wing and tail feathers.251 Male Philippine cockatoos have a brown or black iris while the female has a red iris, while juveniles start with a grey iris changing color as they age.252 These birds make a loud two- syllable call.253

2. Distribution and Range

Philippine cockatoos live primarily in coastal and riparian areas in lowland and secondary forests with populations of mangrove trees.254 They also sometimes live in the surrounding hills and mountains to a height of about 1,000 meters.255 Although nomadic throughout their range, these cockatoos are endemic to the Philippines.256 They are currently found on only a handful of islands within their historic range with population strongholds on the islands of Palawan and Tawitawi.257

3. Life History

These cockatoos are very social - roosting, feeding, and flying in large groups.258 They are noisy birds, especially when encountered in large numbers.259 Breeding season for Philippine cockatoos lasts from March to June, but occasionally stretches from February to August.260 During this time, the birds fly offshore to roost and

249 BirdLife International, Cacatua haematuropygia, available at http://www.BirdLife .org/datazone/search/species_search.html?action=SpcHTMDetails.asp&sid=1403&m=0 (last visited Sept. 19, 2007). 250 United Nations Environment Program, Philippine – Cacatua haematuropygia, available at http://www2.wcmc.org.uk/species/data/species_sheets/philcock.htm (last visited Oct. 10, 2007). 251 Id. 252 Id. 253 Id. 254 IUCN, Cacatua haematuropygia, available at http://www.iucnredlist.org/search/details.php/3427/all (last visited Sept. 19 2007). 255 United Nations Environment Program, Philippine Cockatoo, supra note 250. 256 IUCN, Cacatua haematuropygia, supra note 254; see also BirdLife International, Cacatua haematuropygia, supra note 249. 257 United Nations Environment Program, Philippine Cockatoo, supra note 250. 258 M. Boussekey, An integrated approach to conservation of the Philippine or Red-vented cockatoo, The Zoological Society of London, available at http://www.philippinecockatoo.org/images/marcb.pdf (last visited Oct. 10, 2007). 259 Id. 260 IUCN, Cacatua haematuropygia, supra note 254. 24 breed.261As seasons and food supplies fluctuate, these cockatoos migrate throughout their range.262 They frequent agricultural fields eating both rice and corn.263

4. Abundance and Trend

As recently as the 1950s, Philippine cockatoos were a common sight on the islands.264 However, a rapid decline due to the pet trade and habitat loss has left only about 1,000 to 4,000 birds in the wild.265 Several of the Philippine islands have colonies of less than 200 birds.266 During the 1980s, extensive international legal trading further decimated the population.267 Estimates are that after 1980 the species faced a 60-90% decline in numbers-- due in large part to trapping for the international pet trade.268

5. Threats

The species is listed on CITES Appendix I, and as Critically Endangered on the IUCN Red List.269 The pet trade and habitat loss are the greatest threats to the continued survival of Philippine cockatoos. Trapping on the islands is very common due to the high price paid for each bird on the international market. Because these cockatoos can impersonate a human voice, the pet trade demand is huge.270 In 1997, Philippine cockatoos could fetch around $160 dollars in Manila.271 Species experts agree that trapping is now the greatest threat to Philippine cockatoos’ continued existence.272 In 1996, Palawan authorities confiscated fifty illegally captured birds bound for the international pet trade.273 Manila is a hub for trading these birds with as many as fifty individual birds for sale in one month at the local markets during the mid 90s.274

Conservationists have attempted some and preservation efforts on Palawan, but these birds have a high mortality rate in captivity.275 This is in part due to aggression in these birds when confined.276 Likewise, a high number of wild Philippine cockatoos are reported to have a fungal disease, likely transmitted during mating, that leads to death.277

Widespread and destruction of native mangrove forests has also contributed to population decline.278 Additionally, some Philippine cockatoos have been deemed crop pests or hunted for food. Released captive birds have introduced disease to the wild populations, further pressuring the few remaining individuals.279

261 Id. 262 Id. 263 Id. 264 Id.; see also BirdLife International, Cacatua haematuropygia, supra note 249. 265 Id. 266 Id. 267 BirdLife International, Cacatua haematuropygia, supra note 240; see also IUCN, Cacatua haematuropygia, supra note 254. 268 Boussekey, An integrated approach to conservation of the Philippine or Red-vented cockatoo, supra note 258. 269 Id. 270 Id. 271 BirdLife International, Cacatua haematuropygia, supra note 240. 272 M Boussekey, An integrated approach to conservation of the Philippine or Red-vented cockatoo, supra note 258. 273 Id. 274 Id. 275 United Nations Environment Program, Philippine Cockatoo, supra note 250. 276 Boussekey, An integrated approach to conservation of the Philippine or Red-vented cockatoo, supra note 258. 277 United Nations Environment Program, Philippine Cockatoo, supra note 250. 278 IUCN, Cacatua haematuropygia, supra note 254. 279 Id. 25 I. Red-crowned parrots (Amazona viridigenalis)

(www.schmoker.org/BirdPics/Parrots.html) (http://www.natureserve.org/infonatura/)

1. Description

A large head and bright yellow bill dominate these medium-sized parrots that can reach 33 centimeters in length.280 Red-crowned parrots get their name from their bright red foreheads but their bodies are mostly green and a blue band runs around the back of their brightly colored heads.281 These birds are also known as Green-cheeked parrots.282 The wings are tipped in blue while the tails have yellow ends.283 These parrots have two toes facing each direction, front and back, on grey-green legs.284 Their call is a shrill scream lowering in notes and includes many chattering sounds.285

2. Distribution and Range

Red-crowned parrots are found up to 1,000 meters high.286 Their range is approximately 8,000 square kilometers.287 They prefer lush areas in arid lowlands, the gallery forest and pine-oak ridges, although they are sometimes seen in agricultural areas where large trees are nearby.288 In the wild, these birds are found primarily in small areas of Mexico, and are most commonly seen in the coastal areas of northeast Mexico.289 A former population in Veracruz has disappeared since the early 1960s.290

3. Life History

Red-crowned parrots are known for flying in formation and they gather in large flocks, feeding together and making calls in chorus.291 Their loud calls can be heard for some distance, often long before they are seen,

280 ARKive.org, Amazona viridigenalis, available at http://www.arkive.org/species/GES/birds/Amazona_viridigenalis/more_info.html (last visited Sept. 19, 2007); see also BirdLife International, Amazona viridigenalis, available at http://www.BirdLife .org/datazone/search/species_search.html?action=SpcHTMDetails.asp&sid=1669&m=0 (last visited Sept. 19, 2007). 281 ARKive.org, Amazona viridigenalis, supra note 280. 282 Ernesto Enkerlin-Hoeflich & Kelly M. Hogan, Red-crowned Parrot, The Birds of North America Online, available at http://bna.birds.cornell.edu/bna/species/292/articles/introduction (last visited Jan. 8, 2008) 283 ARKive.org, Amazona viridigenalis, supra note 280; see also BirdLife International, Amazona viridigenalis, supra note 280. 284 ARKive.org, Amazona viridigenalis, supra note 280. 285 BirdLife International, Amazona viridigenalis, supra note 280. 286 IUCN, Amazona viridigenalis, available at http://www.iucnredlist.org/search/details.php/1068/all (last visited Sept. 19, 2007). 287 BirdLife International, Amazona viridigenalis, supra note 280. 288 ARKive.org, Amazona viridigenalis, supra note 280; see also IUCN, Amazona viridigenalis, supra note 286. 289 IUCN, Amazona viridigenalis, supra note 286. 290 Id. 291 ARKive.org, Amazona viridigenalis, supra note 280. 26 and make them easy targets for trappers to locate.292 They are fast flyers and have shallow wing movements.293 Red-crowned parrots are most often seen in pairs and even when flocking, pairs can be readily distinguished within the group.294

They are most active in the mornings and evenings when they feed.295 Their preferred food consists of seeds, berries, and flowers. They also eat .296 During the breeding season, they forage individually, but otherwise they eat in flocks.297 Between the morning and evening feeding sessions, they devote most of their time to cleaning and self-maintenance.298 Mating season lasts between March and May.299 Red-crowned parrots mate in monogamous pairs preferring large trees as nesting sites.300 The pairs usually have between two and five eggs that hatch about twenty-six days later.301 The new chicks leave the nest after seventy days or so.302 In winter, Red-crowned parrots gather in flocks of around 100 birds and move south.303

4. Abundance and Trend

Population estimates range between 3,000 and 6,000 birds left in the wild. As discussed more fully below, pressures from the pet trade and habitat destruction are leading to this species’ extinction.304

5. Threats

This species is listed on CITES Appendix I and is ranked as Endangered on the IUCN Red List due to rapidly declining numbers in the wild.305 The species is also listed as endangered on the Mexican Threatened Species list.306 The pet trade and habitat destruction are the greatest threats to these parrots’ continued existence.307

During a twelve-year span starting in 1970, over 16,000 Red-crowned parrots were imported into the United States alone.308 CITES reports more than 1,800 imports to the US from 1981-2006.309 Currently, illegal exports from Mexico are estimated to be around 5,000 a year.310 As many as half of these birds die before they reach the importing countries; making the numbers introduced as pets likely smaller than those actually taken from the wild.311 Trappers often take all the nestlings they can find, sometimes cutting down the entire tree to get to them.312 This leads to nesting habitat loss, and often means birds will not return to that area to breed next year.313 Likewise, many gallery forests have been removed to make way for agricultural and pasture land further decreasing the available habitat. Over 80% of the suitable forest habitat in some regions of Mexico has been

292 Enkerlin-Hoeflich & Hogan, Birds of North America – Red-crowned parrot, supra note 282. 293 Id. 294 Id. 295 Id. 296 ARKive.org, Amazona viridigenalis, supra note 280. 297 Enkerlin-Hoeflich & Hogan, Birds of North America – Red-crowned parrot, supra note 282. 298 Id. 299 ARKive.org, Amazona viridigenalis, supra note 280. 300 Id. 301 Id. 302 Id. 303 BirdLife International, Amazona viridigenalis, supra note 280. 304 IUCN, Amazona viridigenalis, supra note 286. 305 Id. 306 Audubon Society, Red-crowned Parrot, Audubon Watch List, available at http://www.audubon2.org/watchlist/viewSpecies.jsp?id=170 (last visited Oct. 10, 2007). 307 Enkerlin-Hoeflich & Hogan, Birds of North America – Red-crowned parrot, supra note 282. 308 IUCN, Amazona viridigenalis, supra note 286. 309 Id. 310 Id. 311 Audubon Society, Red-crowned Parrot, supra note 306. 312 ARKive.org, Amazona viridigenalis, supra note 280. 313 Id., see also IUCN, Amazona viridigenalis, supra note 286. 27 cleared for logging, agriculture, and cattle grazing.314 Currently, less than 17% of the original vegetation remains in former Red-crowned parrot habitat, and much of this is on privately held cattle ranches.315

314 Audubon Society, Red-crowned Parrot, supra note 306. 315 N. Snyder, E. Enkerlin-Hoeflich & M. Cruz-Nieto, Birds of North America – Thick-billed Parrot, Cornell University, available at http://bna.birds.cornell.edu/BNA/ (last visited Oct. 10, 2007). 28 J. Scarlet Macaws (Ara macao)

(http://www.animalpicturesarchive.com/view.php?tid=3&did=259435) (http://www.natureserve.org/infonatura/)

1. Description

Scarlet macaws have red heads and shoulders, with a yellow back and mid wings and blue wingtips and tail feathers.316 These macaws have large black beaks, black feet, and yellowish eyes.317 They can reach lengths of up to 89cm with their tail accounting for 1/3 of this.318

2. Distribution and Range

Scarlet Macaws are found in pockets throughout Central and South America and have a range of 6,700,000 km2.319 These birds prefer the high canopy of rainforest below 1,000 meters.320

3. Life History

Scarlet macaws form monogamous pairs, staying with their partners for life.321 These macaws are rarely alone and will gather in large flocks in the evenings to sleep.322 They prefer nests in hollowed out trees of the upper canopy rainforest.323 Scarlet macaws breed about every two years, laying between 2-4 eggs.324 The

316 University of Michigan Museum of Zoology, Ara macao, Animal Diversity Web, University of Michigan, (2007), available at http://animaldiversity.ummz.umich.edu/site/accounts/information/Ara_macao.html (last visited Jan. 8, 2008). 317 Id. 318 Id. 319 Convention on International Trade in Endangered Species of Wild Flora and Fauna (CITES), available at www.cites.org (last visited, Oct. 15, 2007). 320 University of Michigan Museum of Zoology, Ara macao, supra note 316. 321 City Parrots Urban Conservation, Scarlet Macaw, available at www.cityparrots.org (last visited Jan. 8, 2008). 322 University of Michigan Museum of Zoology, Ara macao, supra note 316. 323 Id. 324 Id. 29 females tend to the eggs, and once hatched the males provide food for the young.325 Once fledged the young will stay with their parents for about two years, during which time the adult pair will not breed again.326 Young Scarlet macaws reach sexual maturity after about four years, and these birds are estimated to live 40-50 years in the wild.327

These macaws primarily eat fruit and nuts, and have occasionally been observed using “clay licks.”328 Feeding usually takes place in the early mornings and late afternoons.329 They have been observed eating fruits that are toxic to humans and fruit that other birds will not consume.330 Scarlet macaws play an important role in its ecosystem, as they spread seeds throughout their range as they feed.331

4. Abundance and Trend

Scientists have not quantified the global population of Scarlet macaws.332 The last large study of these birds was in 1997; however, there is evidence of an overall decline in numbers since then.333 In , there are an estimated 300 Scarlet macaws left in a nature preserve there.334 These birds have been completely extirpated in Ecuador.335 A 1996 study in found about 124 of these macaws still in the wild.336 In Costa Rica, as of 2005, only 700 Scarlet macaws live in the Osa Conservation Area and 400 in the Central Pacific Conservation Area.337

5. Threats

Habitat destruction and pet trade captures are the greatest threats to Scarlet macaws, and the species is listed on CITES Appendix I.338 Habitat destruction from forest clearing, settlement and agriculture is common throughout this species’ range.339 Poachers seek out nestlings that can sell locally for hundreds of dollars.340 In the United States, Scarlet macaws sell for more than $1,000 dollars as pets,341 with one website reporting ranges between $1,300-2,500.342 In Guatemala’s Laguna del Tigre National Park, 51 of 53 Scarlet macaw nesting sites where either poached or burned for forest clearing in 2003 alone.343 Biologists from the U.S. working for the Wildlife Conservation Society had to flee the area when armed poachers confronted them.344 This is not an isolated occurrence—heavily armed and determined poachers looking for Scarlet macaws have also threatened

325 Id. 326 Id. 327 Id. 328 Id. 329 Christopher Vaughan, et al., Scarlet Macaw, Ara macao, diet in Central Pacific Costa Rica, 54 INTERNATIONAL JOURNAL OF TROPICAL BIOLOGY 919-26 (2006). 330 Id. 331 University of Michigan Museum of Zoology, Ara macao, supra note 316. 332 BirdLife International, Ara macao, available at http://www.BirdLife .org/datazone/species/index.html?action=SpcHTMDetails.asp&sid=1551&m=0 (last visited Jan. 8, 2008). 333 Id. 334 City Parrots Urban Scarlet Macaw Conservation, Scarlet Macaw, supra note 321. 335 NatureServe, Infonatura, Ara macao, available at ://www.natureserve.org/infonatura/servlet/InfoNatura?sourceTemplate=Ltabular_report.wmt&loadTemplate=Ldetail_report.wmt&select edReport=&summaryView=Ltabular_report.wmt&elKey=649588&paging=home&save=true&startIndex=1&nextStartIndex=1&reset=fa lse&offPageSelectedElKey=649588&offPageSelectedElType=Species&offPageYesNo=true&selectedIndexes=649588 (last visited Jan. 9, 2008). 336 Triangle Metro Zoo of Wake Forest North Carolina, Scarlet Macaw Education, available at www.trianglemetrozoo.com (last visited Nov. 30, 2007). 337 Vaughan, Scarlet Macaw, Ara macao, diet in Central Pacific Costa Rica, supra note 329; see also Christopher Vaughan, Response of a Scarlet macaw Ara macao population to conservation practices in Costa Rica, 15 BIRD CONSERVATION INTERNATIONAL 119-30 (2005). 338 NatureServe, Infonatura, Ara macao, supra note 335. 339 City Parrots Urban Scarlet Macaw Conservation, Scarlet Macaw, supra note 321. 340 Id. 341 University of Michigan Museum of Zoology, Ara macao, supra note 316. 342 Pet Bird Page, Scarlet macaw, available at http://www.petbirdpage.com/breed.asp?breed=scarlet (last visited Jan. 9, 2008). 343 Claudia Orellana, Pets and Parrots, Frontiers in Ecology and the Environment, Vol. 1, No. 6, (2003). 344 Id. 30 researchers in other countries.345 Anti-poaching enforcement is not keeping up with demand and has even made it easier for poachers in some areas. Recently in Costa Rica, parrot poaching was reduced from a felony to a misdemeanor, and the fines imposed were decreased.346 While the overall population of Scarlet macaws is unknown, it is obvious they are threatened by pet trade pressure in many of the countries where they can still be found.

345City Parrots Urban Scarlet Macaw Conservation, Scarlet Macaw, supra note 321. 346 Vaughan, Response of a Scarlet macaw Ara macao population to conservation practices in Costa Rica, supra note 337. 31 K. Thick-billed parrots (Rhynchopsitta pachyrhyncha)

(www.rangefindermag.com/.../Sep05/middleton.tml) (http://www.natureserve.org/infonatura/)

1. Description

Thick-billed parrots are a medium sized bird reaching up to thirty-eight centimeters in length.347 They can weigh as much as four pounds.348 These parrots have bright green bodies, yellow under wings, and red crowns, eye stripes and thighs.349 The birds get their common name from their large heavy bill.350 In juveniles, the beaks start out flesh-colored and then gradually darken as they reach maturity.351 Their calls vary between high-pitched screeches and squawks to screams and laughing calls.352 The laughs sound a lot like human laughter and can be heard for long distances.353 One of their vocalizations can be heard at a distance of two miles.354

2. Distribution and Range

Thick-billed parrots are found almost exclusively in the , Mexico.355 While they were once native to Arizona and New Mexico, wild Thick-billed parrots no longer inhabit this area.356 These parrots prefer temperate conifer, pine, and fir forests in the 1,200-3,600 meter range.357 Today their primary habitat is very small measuring only about 430 square kilometers.358

347 BirdLife International, Rhynchopsitta pachyrhyncha, available at http://www.BirdLife .org/datazone/search/species_search.html?action=SpcHTMDetails.asp&sid=1584&m=0 (last visited Sept. 19, 2007). 348 Phoenix Zoo, Thick-billed Parrot, available at http://www.phoenixzoo.org/learn/animals/animal_detail.aspx?FACT_SHEET_ID=100036 (last visited Oct. 10, 2007). 349 BirdLife International, Rhynchopsitta pachyrhyncha, supra note 347; see also ARKive.org, Rhynchopsitta pachyrhyncha, available at http://www.arkive.org/species/GES/birds/Rhynchopsitta_pachyrhyncha/ (last visited Sept. 19, 2007). 350 Id. 351 Snyder, et al., Birds of North America – Thick-billed Parrot, supra note 315. 352 BirdLife International, Rhynchopsitta pachyrhyncha, supra note 347. 353 Audubon Society, Thick-billed Parrot, Audubon Watch List, available at http://www.audubon2.org/watchlist/viewSpecies.jsp?id=204 (last visited Oct. 10, 2007). 354 Phoenix Zoo, Thick-billed Parrot, supra note 348. 355 ARKive.org, Rhynchopsitta pachyrhyncha, supra note 349. 356 Id. 357 IUCN, Rhynchopsitta pachyrhyncha, available at http://www.iucnredlist.org/search/details.php/19715/all (last visited Sept. 19, 2007). 358 BirdLife International, Rhynchopsitta pachyrhyncha, supra note 349. 32 3. Life History

These parrots feed on pine nuts and seeds with a preference for Douglas fir or Apache pine seeds.359 They gather in flocks in the crowns of the trees where they are feeding and are nomadic following the pinecone crop within their primary habitat.360 They are strong flyers and often fly in a V formation at a great height.361 In the mornings, they gather as small groups then begin a search for food together.362 Although often seen in numbers of seven to eight, flocks of up to 1,000 were observed historically.363 Thick-billed parrots are pine forest specialists relying on this habitat for both food and nesting.364 When feeding one parrot is a designated sentinel and keeps watch while the others forage.365 The flocks go from tree to tree consuming all the pinecones and seeds before moving on.366 They use their strong bills to crack open the pinecone, turning it with their feet as they consume the seeds inside.367

Thick-billed parrots are adapted to the temperate climates where the pine trees on which they feed tend to flourish.368 They can tolerate freezing temperatures and will even feed during snowstorms.369 In the evenings, the parrots huddle together to share warmth.370 Unlike many other parrots, Thick-billed parrots are migratory.371 Some flocks in Mexico have been observed making seasonal migrations.372 They also are nomadic in response to fluctuations in the availability of food.373

Their breeding season is from July to September and corresponds with the time when their food supply is most abundant.374 Roosting takes place on cliffs or in hollowed out trees; usually in abandoned woodpecker dens.375 Breeding only takes place at 2,300 meters or above, with nests around eight to ten feet off the ground in trees reaching up to thirty-five meters high.376 Thick-billed parrots will roost in close proximity to each other, sometimes with only meters separating individual nests.377 These birds lay around three eggs a year and they incubate them for over a month.378 Fledging usually occurs within sixty-five days after birth; however, the chicks remain dependant upon their parents for some time after that.379

4. Abundance and Trend

Thick-billed parrots are the only parrot species alive today whose natural range included the United States. Observations of these parrots were common in Arizona in the late 1800s and early 1900s.380 However,

359 Id. 360 ARKive.org, Rhynchopsitta pachyrhyncha, supra note 349; see also NatureServe, Rhynchopsitta pachyrhyncha, available at http://www.natureserve.org/infonatura/ (last visited Sept. 19, 2007). 361 Phoenix Zoo, Thick-billed Parrot, supra note 348. 362 Id. 363 Id. 364 Id. 365 Id. 366 Snyder, et al., Birds of North America – Thick-billed Parrot, supra note 315. 367 Id. 368 Id. 369 Id. 370 Id. 371 Id. 372 Id. 373 Id. 374 ARKive.org, Rhynchopsitta pachyrhyncha, supra note 349; see also IUCN, Rhynchopsitta pachyrhyncha, supra note 357. 375 Id. 376 NatureServe, Rhynchopsitta pachyrhyncha, available at http://www.natureserve.org/infonatura/servlet/InfoNatura?sourceTemplate=Ltabular_report.wmt&loadTemplate=Ldetail_report.wmt&sel ectedReport=&summaryView=Ltabular_report.wmt&elKey=100639&paging=home&save=true&startIndex=1&nextStartIndex=1&reset =false&offPageSelectedElKey=100639&offPageSelectedElType=Species&offPageYesNo=true&selectedIndexes=100639 (last visited Jan. 8, 2008) 377 Id. 378 ARKive.org, Rhynchopsitta pachyrhyncha, supra note 349. 379 Id. 380 N. Snyder, Birds of North America – Thick-billed Parrot, supra note 315. 33 they were heavily hunted. 100 out of 300 parrots seen in an Arizona canyon in 1917-1918 were shot.381 The last known sighting of wild Thick-billed parrots in the United States was by the FWS in 1938, even though parrots still breed only 100 miles south of the U.S.- Mexico border. Now these parrots are found only in the small and diminishing habitat of the Sierra Madre Occidental.

The population of Thick-billed parrots continues to decline. Estimates were that fewer than 5,000 wild birds existed in 1992. By 1995 that estimate decreased to between 1,000 to 4,000 individuals left in the wild.382 Captive breeding in the United States by the Arizona Game and Fish Department brought 127 chicks to fledging but the reintroduction has largely failed due to disease, predation, and problems developing a flocking behavior in raised birds.383 It is believed that reintroduced parrots in the United States have bred as recently as 1988, but the available data is sparse, and the program was discontinued in 1993 due to the high mortality rate.384

5. Threats

The major threats to Thick-billed parrots are habitat destruction and pet trade activity. The species is listed on CITES Appendix I, considered to be Endangered on the IUCN Red List, and is on the International Endangered Species list in the United States.385 Yet, their numbers continue to decline.

In Mexico, trapping for the pet trade creates a significant stress on the numbers of these parrots.386 Trappers use nets to capture adults, but will also raid the nests.387 Sometimes the entire tree is cut down to reach the nest thus decreasing available nest sites for future breeding.388 Two nest sites under scientific observation in the 1990s had their nestlings poached during the study.389 Because these parrots are so loud, it is easy for hunters to find groups and nests.390 Moreover, they predictably return to the same areas, such as waterfalls, to drink and bathe, making capture easy.

Several breeding and foraging areas of these parrots are protected in Mexico, but enforcement of those protections is limited.391 Due to their attractiveness, these birds have been targeted by the illegal pet trade, with a peak in captures coming in the 1970s and 1980s.392Two experts estimated that in 1987 there were at least 1,000 Thick-billed parrots in captivity, all of which were taken illegally.393

Along with pet trade pressure, these parrots face hardship from habitat loss on a grand scale. Loggers have decimated the old growth forests preferred by Thick-billed parrots. Experts estimated that by 1995, 99.5% of the pine–oak forest in the Sierra Madre Occidental had been logged, either completely or at least selectively.394 This left only about twenty-two square kilometers of old growth forest still intact at the altitude these birds prefer.395 While these birds can persist in partially degraded forests, they cannot survive in the densities known in the recent past.396 Logging and clearing areas for agriculture and cattle grazing have led to severely restricted habitat for these parrots.397

381 Id. 382 BirdLife International, Rhynchopsitta pachyrhyncha, supra note 349. 383 IUCN, Rhynchopsitta pachyrhyncha, supra note 357. 384 Id; see also Arizona Game And Fish Department, Thick-Billed Parrot Report, available at http://www.azgfd.gov/w_c/edits/documents/Rhynpach.d.pdf (last visited Jan. 8, 2008). 385 Id. 386 N. Snyder, Birds of North America – Thick-billed Parrot, supra note 315. 387 Id. 388 Id. 389 Id. 390 Phoenix Zoo, Thick-billed Parrot, supra note 348. 391 IUCN, Rhynchopsitta pachyrhyncha, supra note 357. 392 Id;, see also BirdLife Rhynchopsitta pachyrhyncha, supra note 349. 393 N. Snyder, Birds of North America – Thick-billed Parrot, supra note 315. 394 Id. 395 Id. 396 Id. 397 Id. 34 L. White cockatoos (Cacatua alba)

(http://www.camacdonald.com/birding/WhiteCockatoo (AV).jpg) (http://www.BirdLife.info/wbdbweb/images/speciesmap/2000-1402.gif)

1. Description

White cockatoos are a medium sized bird reaching up to forty-six centimeters in length.398 They can weigh between 500 to 600 grams and have wingspans of up to thirty-one centimeters.399 These birds are predominantly white, with the undersides of the wings and tails having a yellowish tint.400 A distinctive large white crest tops the head.401 This crest accounts for its “umbrella cockatoo” nickname.402 Their small beaks are black while the legs are bluish or grey.403 When perched, these cockatoos make a short high-pitched nasal call; while in flight, they sometimes make rapid lower pitched sounds.404

2. Distribution and Range

These birds are endemic to a few islands in .405 White cockatoos are not nomadic. They reside in primary, secondary, and logged forests up to a height of 900 meters.406 They are also observed on agricultural lands, in mangrove forests and on plantations.407

3. Life History

These cockatoos need a ready supply of large trees for communal roosting and breeding.408 The breeding season coincides with when native plant growth is at its peak, from December to March.409 These cockatoos form breeding pairs that will then search for a suitable tree for nesting.410 The monogamous pairs will

398 BirdLife International, Cacatua alba, available at http://www.BirdLife .org/datazone/search/species_search.html?action=SpcHTMDetails.asp&sid=1402&m=0 (last visited Sept. 19, 2007). 399 E. Lane, Cacatua alba, Animal Diversity Web, available at http://animaldiversity.ummz.umich.edu/site/accounts/information/Cacatua_alba.html (last visited Sept. 19, 2007). 400 Id. 401 Id. 402 Id. 403 BirdLife International, Cacatua alba, supra note 398. 404 Id. 405 IUCN, Cacatua alba, available at http://www.iucnredlist.org/search/details.php/3423/all (last visited Sept. 19, 2007); see also BirdLife International, Cacatua alba, supra note 398. 406 BirdLife International, Cacatua alba, supra note 398. 407 Id. 408 Id. 409 Lane, Cacatua alba, supra note 399. 410 Id. 35 stay together for life.411 White cockatoos have an elaborate courtship ritual that includes the male shuffling his feathers and spreading his wings while puffing out his chest.412 The two mates then begin scratching each other around the face and tail.413

These cockatoos lay between two and three eggs and both parents share responsibility for them.414 Incubation lasts about thirty days and the parents will typically only raise the first healthy chicks born.415 Chicks learn to fly in about three months and will reach sexual maturity in about six years.416

In the afternoon, White cockatoos will gather in large flocks of up to fifty individuals.417 They are social birds, but do not have a set hierarchy nor do they form tight bonds outside of mating pairs.418 They are primarily sedentary birds, but they will travel to find other food sources, such as agricultural fields.419 They communicate with calls and gestures, such as banging on trees with scraps of wood to alert others to their territorial boundaries.420

4. Abundance and Trend

The population of White cockatoos is rapidly declining.421 A 1991 study estimates there were between 43,000 and 183,000 birds left in the wild.422 According to CITES data about 17% of the wild population was plundered for the caged bird trade in 1991 alone.423 At such capture rates, future population declines are assured.

5. Threats

The greatest threats to White cockatoos are the pet trade and habitat destruction. The species is listed on CITES Appendix II, and on the IUCN Red List as Vulnerable.424 The Indonesian government issues catch quotas for these cockatoos, but illegal trapping continues.425

The United States is the single largest importer of wild-caught White cockatoos.426 United States pet traders imported 10,143 of these cockatoos between 1990 and 1999.427 Singapore, South Africa, and Japan imported 6,000 birds in the same period.428 In the United States, pet stores sell individual birds for $1,500 each.429 CITES reports reveal over 41,000 White cockatoos were exported between 1981 and 1984.430 However, these numbers are considered to represent only 25% of the actual captures for the pet trade as many are taken illegally.431 Monitoring of trade volumes in regional pet markets in 1999 revealed numbers of White cockatoos

411 Id. 412 Id. 413 Id. 414 Id. 415 Id. 416 Id. 417 Id. 418 Id. 419 Id. 420 Id. 421 IUCN, Cacatua alba supra note 405; see also BirdLife International, Cacatua alba, supra note 398. 422 IUCN, Cacatua alba, supra note 405. 423 BirdLife International, Cacatua alba, supra note 398. 424 Id. 425 IUCN, Cacatua alba, supra note 405. 426 Lane, Cacatua alba, supra note 399. 427 Id. 428 N.J. Collar, Threatened Birds of Asia – , The BirdLife International Red Data Book, available at http://www.rdb.or.id/detailbird.php?id=47 (last visited Oct. 10, 2007) 429 Id. 430 Id. 431 Id. 36 for sale far greater than the published government capture quota allows.432 Although CITES numbers do not include internal trades of these birds, these numbers are believed to be substantial as well.433

There is only one protected area in the current habitat and this site is threatened by nearby agriculture and the discovery of gold in the area.434 An increase in logging has affected the availability of suitable large tree nesting sites throughout the habitat range.435 The reduction of suitable forest breeding sites and the pet trade are predicted to increase with time.436

432 Id. 433 Id. 434 Lane, Cacatua alba, supra note 399. 435 BirdLife International, Cacatua alba, supra note 398. 436 Id. 37 M. Yellow-billed parrots (Amazona collaria)

(http://www.BirdLife.org/zoom.html?desc=images/photos/b_ye (http://www.natureserve.org/infonatura/) llow-billed_amazon.html&width=&caption)

1. Description

Yellow-billed parrots have primarily green bodies and yellow bills from which they take their common name.437 Their throats are pinkish with white facial markings.438 The birds have high-pitched gurgling calls.439

2. Distribution and Range

Yellow-billed parrots are primarily found in the wet limestone forests of .440 They are nomadic, flying long distances in search of food and can be found as high as 1,200 meters.441

3. Life History

Breeding season for the Yellow-billed parrot lasts from March to August.442 They prefer to make their nests in tree cavities, but have also been observed nesting in rock crevices.443

4. Abundance and Trend

Population estimates for this parrot range between 10,000 and 20,000 left in the wild.444 The remaining population is fragmented due to habitat reduction.445

5. Threats

Yellow-billed parrots face two primary threats--habitat destruction and the pet trade. The species is currently listed on CITES Appendix II, and the IUCN Red List marks it as Vulnerable.446 Habitat reduction

437 BirdLife International, Amazona collaria, available at http://www.BirdLife .org/datazone/search/species_search.html?action=SpcHTMDetails.asp&sid=1661&m=0 (last visited Sept. 19, 2007). 438 Id. 439 Id. 440 IUCN, Amazona collaria, available at http://www.iucnredlist.org/search/details.php/1050/all (last visited Sept. 19, 2007). 441 Id. 442 Id. 443 Id. 444 BirdLife International, Amazona collaria, supra note 437. 445 Id. 446 IUCN, Amazona collaria, supra note 440. 38 because of logging and mining has reduced suitable territory and nest sites for this endemic species.447 Trapping for the pet trade is common.448 Some habitat in Jamaica has been designated national parks, but enforcement of trapping restrictions and funding for research on these parrots are limited.449

447 Id. 448 Id. 449 Id. 39 N. Yellow-crested cockatoos (Cacatua sulphurea)

(www.wwf.org.uk/news/n_0000001338.asp) (http://www.unep-wcmc.org/isdb/Taxonomy/tax-species- result.cfm?SpeciesNo=3433&tabname=distribution)

1. Description

Yellow-crested cockatoos are predominately white, with yellow on the undersides of the wings and tails.450 These medium sized birds can reach lengths of thirty-five centimeters.451 Their most striking feature is a large yellow crest of feathers on the top of the head and a yellow ear covert.452 They have a black bill and grey legs.453 The males have black eyes, while females have eyes of a reddish-brown color.454 These cockatoos make harsh screeches along with whistles and squeaky notes.455

2. Distribution and Range

Yellow-crested cockatoos are endemic to Timor-Leste and Indonesia.456 They prefer evergreen, deciduous, or semi-evergreen forest up to a height of between sea level and 1,200 meters.457 These cockatoos are also seen on the forest edge or on agricultural lands.458

3. Life History

Yellow-crested cockatoos’ diet consists of seeds, berries, nuts, fruits, and flowers.459 They eat many cultivated crops as well, and have been seen feeding in the lower canopy and from the ground.460 Scientific data on their breeding habits is very limited.461 Like all cockatoos, these birds develop strong pair bonds as well as

450 ARKive.org, Cacatua sulphurea, available at http://www.arkive.org/species/GES/birds/Cacatua_sulphurea/more_info.html (last visited Sept. 19, 2007)., see also BirdLife International, Cacatua sulphurea, available at http://www.BirdLife .org/datazone/search/species_search.html?action=SpcHTMDetails.asp&sid=1398&m=0 (last visited Sept. 19, 2007). 451 BirdLife International, Cacatua sulphurea, supra note 450. 452 Id. 453 ARKive.org, Cacatua sulphurea, supra note 450. 454 Id. 455 BirdLife International, Cacatua sulphurea, supra note 450. 456 IUCN, Cacatua sulphurea, available at http://www.iucnredlist.org/search/details.php/3433/all (last visited Sept. 19, 2007). 457 Id; see also ARKive.org, Cacatua sulphurea, supra note 450. 458 Id. 459 ARKive.org, Cacatua sulphurea, supra note 450. 460 N.J. Collar, et al., Yellow-crested cockatoo, in THREATENED BIRDS OF ASIA: THE BIRDLIFE INTERNATIONAL RED DATA BOOK (Cambridge University Press 2002). 461 ARKive.org, Cacatua sulphurea, supra note 450. 40 roost and feed in groups.462 Nests are usually located in tree hollows and in cliff faces.463 Up to three eggs are usually laid, and they hatch within thirty days.464

4. Abundance and Trend

Populations of Yellow-crested cockatoos have experienced rapid decline in the past thirty years. While once common on the many islands of its range, these birds are now extinct on all but five of them.465 Population estimates place the number of birds remaining in the wild at between 2,500 and 10,000 individuals.466 The island of Sumba has the largest remaining numbers of birds with 1992 estimates of around 3,200.467 A recent comparison of a 1992 study and follow-up 2002 study estimated one population of these birds to be between 500-2,000 individuals.468 It is estimated that the decline in number of these cockatoos amounts to an almost 80% reduction over three generations.469

5. Threats

The startling decline of Yellow-crested cockatoos is directly traceable to trapping for the pet trade.470 Demand for these birds as pets is both internal and international.471 Evidence suggests that the international trade has placed the highest pressure on their wild numbers.472 During the 1980s, regular trade in these birds was established in San Francisco in the United States.473 CITES import numbers for these birds between 1981 and 1985 amount to more than 21,000.474 Indonesia reported more than 96,000 had been exported for the ten years before 1992.475 In 1993, export of the species became illegal but as recently as 1999 as many as twenty birds per month were available for purchase at an international bird market in Singapore.476 In 1998, Yellow- crested cockatoos could be bought for about $50 on the Indonesian mainland.477

In the 1990s CITES and local authorities decided not to place this bird on Appendix I and to control its population instead by using quotas.478 These quotas were set to zero in 1994 yet trading remains steady to date.479 From 1993-2004 Indonesia reported the export of 712 Yellow-crested cockatoos while CITES nations recorded an actual import of more than 1,600 for the same period.480

Capture techniques vary but sometimes tame decoy birds are used to lure in wild Yellow-crested cockatoos.481 Snares are then used to trap the adults.482 Nests are also raided for chicks.483 It is estimated that only one in five of captured cockatoos makes it to a pet trade wholesaler alive.484 On many of the Indonesian

462 Id. 463 Id. 464 Id. 465 Id. 466 BirdLife International, Cacatua sulphurea, supra note 450. 467 IUCN, Cacatua sulphurea, supra note 456. 468 A. Cahill, J. Walker, & S. Marsden, Recovery within a population of Critically Endangered citron-crested cockatoo Cacatua sulphurea citrinocristata in Indonesia after 10 years of International trade control, 40 ORYX 161-167 (2006). 469 IUCN, Cacatua sulphurea, supra note 456. 470 Id. 471 Id. 472 Collar, et al., Yellow-crested cockatoo, supra note 460. 473 Id. 474 Id 475 Id. 476 Id. 477 Id. 478 Cahill, Walker, & Marsden, Recovery within a population of Critically Endangered citron-crested cockatoo, supra note 468. 479 Id. 480 Id. 481 Collar, et al., Yellow-crested cockatoo, supra note 460. 482 Id. 483 Id. 484 Id. 41 islands, this bird was trapped to extinction.485 Today a few protected areas offer some sanctuary for Yellow- crested cockatoos but they are not present there in any large numbers.486

Habitat loss due to logging and agricultural conversion of forestland and persecution as crop pests has also placed pressure on the remaining numbers of wild birds.487 Yellow-crested cockatoos are now listed on CITES Appendix I and are considered Critically Endangered by the IUCN Red List.488

485 Id. 486 Id. 487 IUCN, Cacatua sulphurea, supra note 456. 488 Id. 42 V. Analysis of Endangered Species Act Listing Factors

Pursuant to the ESA §1533(a)(1), the Secretary is required to list a species for protection if it is in danger of extinction or threatened by possible extinction in all or a significant portion of its range. In making this decision, the Secretary must analyze the species’ status based on any of the five listing factors. Because three out of the five factors affect all of the petitioned species, Petitioners will discuss the three specifically applicable factors in depth below. Other threats are summarized in the species accounts above and are more fully detailed in the information available from BirdLife International, NatureServe and the IUCN, which have been incorporated into this petition.

A. The Present or Threatened Destruction, Modification, or Curtailment of Habitat or Range;

The bird species in this petition face pressure from habitat destruction in some form. Forest logging, clearing for agriculture and cattle grazing are the most common threats. While these affect each species differently, common trends appear.

Logging reduces forest cover where many of these species feed. As described above, some of these birds depend on certain tree fruits as their primary food source. Additionally most of the birds require old growth trees with existing cavities in them for nesting purposes. Clear cutting may remove entire forest habitats, and unfortunately, good trees for nesting are often good trees for selective logging. In addition to removing food and nesting sites, logging can make available habitat smaller. Some of the birds in this petition depend on large canopy forest for their range.

Clearing land for agriculture also threatens the continued survival of many of these macaw, parrot, and cockatoo species. Forest conversion o cropland removes nesting and feeding sites. The presence of crops on the edge of a bird’s habitat may cause conflict between humans and birds. Several of these species have been observed feeding on crops, especially maize. Many of the petitioned species are currently persecuted as crop pests, and as more forestland is converted to agriculture, this trend will likely continue.

Cattle grazing also affects several of the birds in this petition. Those species dependent on a few specific trees as food sources are the most impacted by cattle grazing in or near their habitat. In addition to the clearing of forest for pastureland, grazing cows often eat or trample tree saplings. This impedes growth and replacement of trees a particular bird may need for their continued survival.

Of course, the particularized impacts of habitat destruction on each species vary, but all of the birds here face current or projected harms relating to habitat loss. The above species accounts provide concrete examples for each bird, but generally, logging, agriculture, and cattle grazing pressures are common. As the countries of origin for the petitioned species continue to develop, habitat pressures will undoubtedly increase.

B. Over-utilization for Commercial, Recreational, Scientific, or Educational Purposes—the Pet Trade

The illegal trade in CITES listed birds is estimated to be worth anywhere from five to eight billion dollars.489 Trappers acting illegally and legally capture the species in their native lands, transport them, and sell them to pet stores and exotic pet auction houses all over this country.490 Although some states have laws and

489 Royal Society for the Prevention of Cruelty to Animals, It’s Time to Stop Winging It. June 2006, available at http://www.rspca.org.uk/servlet/BlobServer?blobtable=RSPCABlob&blobcol=urlblob&blobkey=id&blobwhere=1147695606619&blobh eader=application/pdf (last visited December 19, 2007). 490 For example, in 2003, US Customs inspectors discovered forty-four birds strapped to a man’s legs. The man was charged with lying on a customs declaration form and released the next day on $50,000 bond. Georgia Department of Human Resources, Public Health and You – A bird in the Hand is Worth…, available at http://health.state.ga.us/healthtopics/mme/020904.asp (last visited December 19, 2007). 43 regulations that pertain to the pet trade, most do not.491 Therefore, unless the Secretary lists the petitioned species as endangered species under the ESA, the pet trade will continue to threaten the species and lead to their extinction.

Trappers capture birds in their native habitat, which, in the case of these petitioned species taken together, comprises pockets of land all over the world.492 Bird species in particular are extremely vulnerable to trapping due to their low reproductive rates.493 Therefore, the pet trade harms the species through prevention of natural reproduction, and high mortality rates due to legal and illegal removals of birds from their habitats. Although specific statistics are sometimes hard to locate due to the illegal nature of most of the trapping, studies indicate that mortality during capture rates for birds in particular are higher than for other species.494

Mortality rates are high for wild-captured birds in the pet trade because captured animals are free to those who capture them.495 Therefore, there is no incentive to ensure that the “product” is delivered alive.496 If at least some of the birds survive, the fact many of them die is immaterial.497 The initial shock of losing their freedom and being confined to a cage can kill up to 66% of wild-captive birds.498 Of those who survive, approximately half will die of starvation, dehydration, suffocation, or disease before reaching their destination.499 Researchers in Nicaragua estimate that to compensate for mortalities, up to four times as many parrots are captured in the wild as make it to market.500 Similarly, a 1992 investigation conducted by a British environmental agency indicated that up to three birds die for every one that reaches a pet shop.501

Once the birds are trapped, they must be transported to the import countries. The wealthiest nations, including the United States, are the largest consumers of animals for the pet trade.502 In the United States, approximately 6% of households have at least one bird.503 Because people who buy birds as pets cannot distinguish between wild-caught animals and those bred in captivity, there is no way to allow the sale of these birds while at the same time curbing the pet trade in wild caught birds.

Live animals covered by the CITES treaty must be shipped to importing countries in accordance with International Air Transport Association (“IATA”) guidelines.504 However, in the United States, fewer than 25% of live animal shipments are inspected by Service agents.505 Similarly, when the Service discovers violations of the IATA guidelines, agents typically give warnings instead of taking stricter measures allowed by law.506

491 Animal Protection Institute, Current Law and Suggested Approaches to Improving Captive Bird Welfare, available at http://www.api4animals.org/b4a2_birdwelfare.php (last visited Oct, 15, 2007). 492 See Table A. 493 Alan J. Hesse & Giles E. Duffield, The Status and Conservation of the Blue-Throated Macaw Ara Glaucogularis, 10 BIRD CONSERVATION INTERNATIONAL 255, 267 (2000). 494Id. (Explaining that Finches and Waxbills captured in Senegal experience a 40%-50% mortality rate prior to export and 31% of birds captured in Tanzania die before export). 495 Royal Society for the Prevention of Cruelty to Animals, It’s Time to Stop Winging It. June 2006, available at http://www.rspca.org.uk/servlet/BlobServer?blobtable=RSPCABlob&blobcol=urlblob&blobkey=id&blobwhere=1147695606619&blobh eader=application/pdf (last visited December 19, 2007). 496 Id. 497 Id. 498 Animal Protection Institute, The Dirty Side of the Exotic Animal Pet Trade, Animal Issues, Vol. 31, Num. 1 (Spring 2000). 499 Id. 500 Id. 501 Animal Aid, From Rainforest to Retail, January 2002, available at http://www.animalaid.org.uk/h/n/CAMPAIGNS/pet_trade/ALL/433/ (last visited Oct. 15, 2007) citing EIA Flight to Extinction, Wild- caught Bird Trade, Environmental Investigation Agency London, 1992. 502 Humane Society of the United States, Wildlife Trade, available at http://www.hsus.org/wildlife/issues_facing_wildlife/wildlife_trade/ (last visited Oct. 15, 2007). 503 Humane Society of the United States, Live Cargo, available at http://www.hsus.org/wildlife/issues_facing_wildlife/wildlife_trade/live_cargo.html (last visited Jan. 9, 2008). 504 Id.; see also CITES, Guidelines for Transport, available at http://www.cites.org/eng/resources/transport/index.shtml (last visited December 18, 2007). 505 Id. 506 Id. 44 “Consequently, there is little incentive for those engaged in the live bird trade to comply with the current law, even when that trading is legal under CITES.”507

Another way that smugglers get around CITES regulations is by engaging in “bird laundering.” Smugglers take birds out of their native countries where they are protected, and smuggle them into countries where fewer restrictions exist.508 Export documents are then secured in the second country so the birds can be “legally” traded and transported to other nations.509 Because valid export documents are obtained, these birds can enter the United States legally.

Of the birds that survive transport, the majority of them are “severely stressed” and many die within one year of import.510 A contributing factor to the mortality rate in the United States is that birds must be quarantined for thirty days after arrival.511 According to United States government records, an average of 10% of the birds die within the 30-day quarantine period, and many others are killed because they are found to harbor viruses dangerous to United States agriculture.512 Once the birds are released from quarantine, they are either sold in pet stores or sold at auctions across the United States.513

Overall, the pet trade threatens the survival of the species by subjecting them to capture and export from their native countries and then subjecting them to the hardships of transport, import, and life in a cage. Because the pet trade is the linking threat to all of the petitioned species, the Secretary should list the petitioned species as endangered species under the ESA and thus protect then in this country. Because the United States is a huge consumer of birds from the pet trade, listing the species as endangered species is the only measure that could save these species from extinction.

C. The Inadequacy of Existing Regulatory Mechanisms

The problem with the existing regulatory mechanisms is that once an individual purchases one of the petitioned species, none of the existing laws makes it illegal to possess that bird. Although CITES, the Lacey Act, and the Wild Bird Conservation Act restrict trading the petitioned species, these regulatory mechanisms have not adequately protected these birds in the wild. Because these regulations are not curtailing the pet trade, the current regulatory mechanisms are not adequately protecting the species.

1. The Inadequacy of CITES in the Protection of the Species

CITES was adopted in 1973 and implemented in 1975.514 171 countries are parties to CITES.515 CITES aims to protect species from the detrimental effects of international trade by establishing an international legal framework for preventing and controlling trade.516 CITES works by subjecting international trade in specimens of selected species to certain controls.517 All import, export, re-export and introduction of the species covered by CITES has to be authorized through a licensing system. CITES lists all of the petitioned species under either Appendix I or Appendix II.518 Appendix I includes species threatened with extinction, and trade in specimens of

507Id.; International Parrotlet Society, Bird Smuggling, available at http://www.internationalparrotletsociety.org/smuggle.html (last visited, Oct. 15, 2007). 508 Id. 509 Id. 510 Id. 511 Id. 512 Id. 513 Animal Protection Institute, The Dirty Side of the Exotic Animal Pet Trade, supra note 498. 514 BirdLife International, CITES and the Wild Bird Trade, supra note 19. 515 Id. 516 Id. 517Convention on International Trade in Endangered Species of Wild Flora and Fauna (CITES), available at www.cites.org (last visited, Oct. 15, 2007). 518 See Table B. 45 these species is permitted only in exceptional circumstances.519 Appendix II includes species not necessarily threatened with extinction, but in which trade must be controlled in order to avoid utilization incompatible with their survival.520

Although all of the petitioned species are listed under Appendix I or II, these birds can still be traded legally with permits, and are traded illegally through trafficking.521 For Appendix I species to be traded, an import permit must be issued by the Management Authority of the State of Import.522 A permit may be issued only if the specimen is not to be used for primarily commercial purposes and if the import will be for purposes that are not detrimental to the survival of the species.523 For Appendix II species, no import permit is needed unless required by national law.524 Therefore, Appendix II species can be legally imported in the United States unless they are listed as endangered species under the ESA.

Although permits are not typically issued for species listed in Appendix I, illegal trapping and trading is rampant.525 According to BirdLife International, the Philippine cockatoo is listed in Appendix I of CITES because trappers illegally traded the bird so that sustainable levels do not exist in the wild.526 Attempts made to regulate the take have not been successful, and as the adult population ages and dies off, the species heads towards extinction.”527

Specific figures on the magnitude of the illegal bird trade are not available, but statistics are not necessary to appreciate the ecological damage and the profound social, conservation, and humanitarian concerns of the carnage.528 The world is losing rainforest habitat to the poaching trade as trees are hacked down to get at nests.529 Similarly, parent birds are typically killed to get to nestlings.530 All of this destruction continues to happen despite the CITES regulations.

A further problem with the current CITES regulations is that the Secretariat of CITES does not acknowledge that CITES is ineffective in controlling the international bird trade.531 In January of 2007, the European Union (EU) announced an indefinite ban on imports of wild birds because it will prevent the spread of avian flu.532 CITES released a statement disagreeing with the ban on the basis that CITES already effectively controls the international bird trade thus additional measures are not needed.533 This position is disturbing as the organizations used by CITES to make listing decisions (namely BirdLife International) agree that although CITES helps control the international bird trade there is still a substantial amount of illegal trading despite the regulations.534

519 Convention on International Trade in Endangered Species of Wild Flora and Fauna (CITES), available at www.cites.org (last visited, Oct. 15, 2007). 520 Id. 521 Daniel Hammer, Behind the Bird Trade, available at http://www.friendsofanimals.org/actionline/summer-2006/behind-the-bird- trade.php (last visited Jan. 13, 2008). 522 CITES, How CITES Works, available at http://www.cites.org/eng/disc/how.shtml (last visited Oct. 15, 2007). 523 Id. 524 Id. 525 Hammer, Behind the Bird Trade, supra note 521. 526 BirdLife International, BirdLife International’s position on proposal 11 to transfer Yellow-crested cockatoo From Appendix II to Appendix I, available at http://www.BirdLife .org/action/change/cites/yellow-crested_cockatoo.pdf (last visited December 18, 2007). 527 Id. 528 Animal Protection Institute, The Cruelty of the Wild Bird Trade, Animal Issues, Vol. 31, Num. 1 (Spring 2000), available at http://www.api4animals.org/articles.php?p=177&more=1 (last visited Oct. 15, 2007). 529 Lorin Lindner, Free as a Bird, Animal Issues, Vol. 31. Num. 1 (Spring 2000), available at http://www.api4animals.org/articles.php?p=175&more=1 (last visited Oct. 15, 2007). 530 Id. 531 CITES, Press Release: EU Ban on Wild Bird Imports “Disappointing,” available at http://www.cites.org/eng/news/press/2007/070111_EU_bird_ban.shtml (last visited Oct. 15, 2007) 532 Id. 533 Id. 534 BirdLife International, CITES and the Wild Bird Trade, supra note 19. 46 2. Other Inadequate Regulatory Mechanisms

In the United States, CITES is enforced by the Lacey Act and the Wild Bird Conservation Act. The Lacey Act makes it “illegal for a person to import, export, transport, sell, receive, acquire, or purchase in interstate or foreign commerce: fish or wildlife taken, possessed, transported or sold in violation of a state law, state regulation of foreign law.”535 However, statistics make it evident that the Lacey Act has been unable to stop the trade of the species in the United States as their numbers continue to decline in the wild. Similarly, the Wild Bird Conservation Act, although specifically adopted to deal with the pet trade and inadequacy of CITES regulations, fails to stop or even slow the pet trade.536 The statistics for all of the species show a continued steady decline since the Wild Bird Conservation Act was adopted and implemented.537

Since the Wild Bird Conservation Act was implemented, only one case of its enforcement was reported.538 The general lack of enforcement under Wild Bird Conservation Act despite the large numbers of birds imported into the United States illegally shows the inadequacy of this regulation. However, the Wild Bird Conservation Act does recognize that the pet trade causes habitat loss and high mortality rates despite the current CITES regulations.539 This recognition represents an important admission by Congress that CITES is inadequate.

Despite CITES and the United States regulations enforcing CITES, up to 150,000 parrots are illegally smuggled into the United States across the Mexican border each year. 540 All told, every year nearly 4,000 species involving several million individual birds are subjected to international or domestic trade.541 Statistics from before the year 2000 suggest that 20 million wild-caught birds are illegally smuggled per year worldwide.542

In one recent example, 149 exotic parrots protected by United States and international laws were confiscated from smugglers at the United States border with Mexico.543 In an article discussing why parrots are smuggled into the United States, the Service acknowledged that the high demand for parrots in the United States provides an irresistible incentive for smugglers to profit at the birds’ expense.544 The Service admitted that the birds returned to Mexico from this incident represent only a handful of the untold thousands of threatened and endangered wildlife that end up in the illegal trade each year.545 "In the case of parrots, smugglers typically cross the U.S-Mexico border and conspire with certain exotic pet retailers or travel to swap meets to sell the birds at a lower price than legally obtained birds. People buy them because they are significantly cheaper and rarely ask about their origin."546 In the article, the Service admitted further that these birds are trapped and traded, regardless of the protection and regulation afforded by CITES.547

A second illustration of the inadequacy of the current regulations is the Service’s successful break-up of an international smuggling ring dealing in CITES protected birds in 1998.548 The three-year investigation, code-

535 16 U.S.C. §§1371-3378 (November 1981, as amended 1984 and 1988). 536 16 U.S.C. §4901 (1992). 537 See Species Accounts, supra Section IV. 538 See United States v. Cullen, 2007 WL 2445123 (2nd Cir. Ct. App 2007) (Defendant was convicted of knowingly importing exotic birds into the United States in violation of the Wild Bird Conservation Act). 539 Robert S. Anderson, The Lacey Act: America’s Premier Weapon in the Fight Against Unlawful Wildlife Trafficking, 16 PUB. LAND L. REV. 27 (1995). 540 Animal Protection Institute, Dirty Side of the Exotic Animal Pet Trade, supra note 498. 541 BirdLife International, CITES and the Wild Bird Trade, supra note 19. 542 Lindner, Free as a Bird, supra note 529. 543 Unite States Fish and Wildlife Service, Exotic Parrots Seized from Smugglers Returned to Mexico (Fall 2007), available at http://www.fws.gov/news/NewsReleases/showNews.cfm?newsId=8ED7D2C7-0950-F2DB-9DB30E5A956367E5 (last visited Oct. 15, 2007). 544 Id. 545 Id. 546 Id. 547 Id. 548 United States Fish and Wildlife Service, Federal Agents Target Illegal Bird Trade, (May 29, 1998), available at http://www.internationalparrotletsociety.org/smuggle.html (last visited, Oct. 15, 2007). 47 named Operation Jungle Trade, resulted in the seizure of more than 660 exotic birds.549 After the seizure, the Service stated that “the United States is the world’s largest market for wildlife and wildlife products, but this demand cannot be met at the expense of the world’s animal and plant species.”550 Moreover, for that reason, the Service must list the petitioned species both domestically and internationally to ensure that the demand for these birds does not result in the extinction of any of the petitioned species.

Both of the above illustrations of the inadequacies of the current regulations have happened since the implementation of the Wild Bird Conservation Act. Although CITES, the Lacey Act, and the Wild Bird Conservation Act are no doubt positive forces in the fight against the international trade of threatened and endangered birds, the current regulations are not effectively controlling the problem. Standing alone, these regulations are not able to ensure that the petitioned species will not become extinct due to the legal and illegal pet trade.

Because the current regulatory mechanisms are inadequate, it is necessary to list the petitioned species both domestically and internationally under the ESA. The ESA is the only mechanism that can adequately curtail the pet trade by making it illegal to buy, sell, or possess one of the petitioned species in the United States. 16 U.S.C. § 1538(a). One of the species, the Thick-billed parrot, is already listed internationally under the ESA.551 However, the data shows that because of the pet trade the international listing alone has not adequately protected the species. The numbers of thick-billed parrots in the wild have continued to decline since 1970. Specifically, the data shows that in 1992 fewer than 5,000 birds existed in the wild, and by 1995 that estimate was downgraded to between 1,000 and 4,000 individuals left in the wild. Therefore, there is no data to show that numbers have increased since the Secretary listed the birds internationally. Therefore, the data shows that international listing is inadequate, and because domestic listing will discourage people from purchasing these parrots as pets, domestic listing under the ESA is the only way to curb the pet trade and adequately protect the species.

Although all of the species addressed herein are listed under Appendix I or Appendix II of CITES, all of these species continue to decline. Although CITES is reporting that the numbers of birds imported to the United States through the pet trade is decreasing, quarantine data shows that numbers are holding steady and are sometimes on the rise. This is the case although it is illegal to import many of the species because they are listed on Appendix I of CITES. Between 1981 and 1984 CITES reported that 702 hyacinth Macaws entered the United States, while quarantine sources for the same period show that 1,382 birds were imported in the United States—indicating that CITES declarations are far lower than the actual import numbers.

VI. Conclusion

Because the legal and illegal trapping for the cage-bird trade has rendered all of the petitioned species anywhere from vulnerable to critically endangered according to the IUCN Red List, the Service must list the petitioned species domestically and internationally under the ESA to prevent extinction. Petitioners request that the Service make a positive ninety-day finding on this petition and proceed with a status review for each of the petitioned species. All of the information that is required to make such a finding is readily available through the three scientific databases incorporated into this petition and constitutes “substantial scientific and commercial information indicating that listing may be warranted.” Furthermore, Petitioners request that the Service designate critical habitat in the U.S. for the Thick-billed parrot. Petitioners hope that the Service will act on this petition quickly before one or more of these petitioned species becomes extinct.

549 Id. 550 Id. 551 The Thick-billed parrot was listed internationally under the ESA in 1970. 45 Fed. Reg. 49844 (July 25, 1980). 48 Respectfully submitted this 29th day of January 2008.

Kay Bond Attorney-at-Law Environmental Law Clinic Student Law Office University of Denver Sturm College of Law 303.871.6140 [email protected]

COUNSEL FOR FRIENDS OF ANIMALS

49

Table A

Common Name Scientific Name Threats Blue-throated macaw Ara glaucogularis Pet trade exploitation Habitat destruction Inadequate Regulatory Measures Blue-headed macaw Propyrrhura couloni Pet trade exploitation Low reproduction Habitat destruction Inadequate Regulatory Measures Crimson shining parrot Prosopeia splendens Pet trade exploitation Habitat destruction Inadequate Regulatory Measures Great green macaw Ara ambiguous Pet trade exploitation Habitat destruction Inadequate Regulatory Measures Grey-cheeked parakeet Brotogeris pyrrhoptera Pet trade exploitation Habitat destruction Inadequate Regulatory Measures Hyacinth macaw Anodorhynchus Pet trade exploitation hyacinthinus Habitat destruction Local food source Inadequate Regulatory Measures Military macaw Ara militaris Pet trade exploitation Habitat destruction Inadequate Regulatory Measures Philippine cockatoo Cacatua haematuropygia Pet trade exploitation Habitat destruction Local food source Crop-pest persecution Red-crowned parrot Amazona viridigenalis Pet trade exploitation Habitat destruction Inadequate Regulatory Measures Scarlet macaw Ara macao Pet trade exploitation Habitat destruction Inadequate Regulatory Measures Thick-billed parrot Rhynchopsitta Pet trade exploitation pachyrhyncha Habitat destruction Inadequate Regulatory Measures White cockatoo Cacatua alba Pet trade exploitation Habitat destruction Inadequate Regulatory Measures Yellow-billed parrot Amazona collaria Pet trade exploitation Habitat destruction Inadequate Regulatory Measures Yellow-crested cockatoo Cacatua sulphurea Pet trade exploitation Habitat destruction Crop-pest persecution Inadequate Regulatory Measures

Table B

Name CITES NatureServe IUCN Red List Classification Classification Classification Blue-headed Appendix II G2 Endangered macaws Blue-throated Appendix I G1 Critically macaw Endangered Crimson Appendix II None Vulnerable shining parrots Great green Appendix I VU Endangered macaws Grey-cheeked Appendix II None Endangered parakeets Hyacinth Appendix I G2 Endangered macaws Military Appendix I G3 Vulnerable macaws Philippine Appendix I None Critically cockatoos Endangered Red-crowned Appendix I G2 Endangered parrots Scarlet macaws Appendix I None Least Concern Thick-billed Appendix I G2G3 Endangered parrots White Appendix II None Vulnerable cockatoos Yellow-billed Appendix II G2 Vulnerable parrots Yellow-crested Appendix I None Critically cockatoos Endangered

Table C

Category Criteria For Listing CRITICALLY A taxon is Critically Endangered when the best available ENDANGERED (CR) evidence indicates that it meets any of the following criteria A taxon is Critically Endangered when the best (A to E), and it is therefore considered to be facing an available evidence extremely high risk of extinction in the wild: indicates that it meets any of the criteria A to E for A. Reduction in population size based on any of the Critically Endangered (see following: Section V), and it is therefore considered to be 1. An observed, estimated, inferred or suspected population facing an extremely high size reduction of 90% over the last 10 years or three risk of extinction in the generations, whichever is the longer, where the causes of the wild. reduction are clearly reversible AND understood AND ceased, based on (and specifying) any of the following: (a) direct observation (b) an index of abundance appropriate to the taxon (c) a decline in area of occupancy, extent of occurrence and/or quality of habitat (d) actual or potential levels of exploitation (e) the effects of introduced taxa, hybridization, pathogens, pollutants, competitors or parasites. 2. An observed, estimated, inferred or suspected population size reduction of 80% over the last 10 years or three generations, whichever is the longer, where the reduction or its causes may not have ceased OR may not be understood OR may not be reversible, based on (and specifying) any of (a) to (e) under A1. 3. A population size reduction of 80%, projected or suspected to be met within the next 10 years or three generations, whichever is the longer (up to a maximum of 100 years), based on (and specifying) any of (b) to (e) under A1. 4. An observed, estimated, inferred, projected or suspected population size reduction of 80% over any 10 year or three generation period, whichever is longer (up to a maximum of 100 years in the future), where the time period must include both the past and the future, and where the reduction or its causes may not have ceased OR may not be understood OR may not be reversible, based on (and specifying) any of (a) to (e) under A1.

B. Geographic range in the form of either B1 (extent of occurrence) OR B2 (area of occupancy) OR both: 1. Extent of occurrence estimated to be less than 100 km², and estimates indicating at least two of a-c: a. Severely fragmented or known to exist at only a single

1 location. b. Continuing decline, observed, inferred or projected, in any of the following: (i) extent of occurrence (ii) area of occupancy (iii) area, extent and/or quality of habitat (iv) number of locations or subpopulations (v) number of mature individuals. c. Extreme fluctuations in any of the following: (i) extent of occurrence (ii) area of occupancy (iii) number of locations or subpopulations (iv) number of mature individuals. 2. Area of occupancy estimated to be less than 10 km², and estimates indicating at least two of a-c: a. Severely fragmented or known to exist at only a single location. b. Continuing decline, observed, inferred or projected, in any of the following: (i) extent of occurrence (ii) area of occupancy (iii) area, extent and/or quality of habitat (iv) number of locations or subpopulations (v) number of mature individuals. c. Extreme fluctuations in any of the following: (i) extent of occurrence (ii) area of occupancy (iii) number of locations or subpopulations (iv) number of mature individuals.

C. Population size estimated to number fewer than 250 mature individuals and either: 1. An estimated continuing decline of at least 25% within three years or one generation, whichever is longer, (up to a maximum of 100 years in the future) OR 2. A continuing decline, observed, projected, or inferred, in numbers of mature individuals AND at least one of the following (a-b): (a) Population structure in the form of one of the following: (i) no subpopulation estimated to contain more than 50 mature individuals, OR (ii) at least 90% of mature individuals in one subpopulation. (b) Extreme fluctuations in number of mature individuals.

D. Population size estimated to number fewer than 50 mature individuals.

E. Quantitative analysis showing the probability of extinction in the wild is at least 50% within 10 years or three generations, whichever is the longer (up to a maximum of 100 years).

2 ENDANGERED (EN) A taxon is Endangered when the best available evidence A taxon is Endangered indicates that it meets any of the following criteria (A to E), when the best available evidence indicates that it and it is therefore considered to be facing a very high risk of meets any of the criteria A extinction in the wild: to E for Endangered (see Section V), and it is A. Reduction in population size based on any of the therefore considered to be following: facing a very high risk of extinction in the wild. 1. An observed, estimated, inferred or suspected population size reduction of 70% over the last 10 years or three generations, whichever is the longer, where the causes of the reduction are clearly reversible AND understood AND ceased, based on (and specifying) any of the following: (a) direct observation (b) an index of abundance appropriate to the taxon (c) a decline in area of occupancy, extent of occurrence and/or quality of habitat (d) actual or potential levels of exploitation (e) the effects of introduced taxa, hybridization, pathogens, pollutants, competitors or parasites. 2. An observed, estimated, inferred or suspected population size reduction of 50% over the last 10 years or three generations, whichever is the longer, where the reduction or its causes may not have ceased OR may not be understood OR may not be reversible, based on (and specifying) any of (a) to (e) under A1. 3. A population size reduction of 50%, projected or suspected to be met within the next 10 years or three generations, whichever is the longer (up to a maximum of 100 years), based on (and specifying) any of (b) to (e) under A1. 4. An observed, estimated, inferred, projected or suspected population size reduction of 50% over any 10 year or three generation period, whichever is longer (up to a maximum of 100 years in the future), where the time period must include both the past and the future, and where the reduction or its causes may not have ceased OR may not be understood OR may not be reversible, based on (and specifying) any of (a) to (e) under A1.

B. Geographic range in the form of either B1 (extent of occurrence) OR B2 (area of occupancy) OR both: 1. Extent of occurrence estimated to be less than 5000 km², and estimates indicating at least two of a-c: a. Severely fragmented or known to exist at no more than five locations. b. Continuing decline, observed, inferred or projected, in any of the following:

3 (i) extent of occurrence (ii) area of occupancy (iii) area, extent and/or quality of habitat (iv) number of locations or subpopulations (v) number of mature individuals. c. Extreme fluctuations in any of the following: (i) extent of occurrence (ii) area of occupancy (iii) number of locations or subpopulations (iv) number of mature individuals. 2. Area of occupancy estimated to be less than 500 km², and estimates indicating at least two of a-c: a. Severely fragmented or known to exist at no more than five locations. b. Continuing decline, observed, inferred or projected, in any of the following: (i) extent of occurrence (ii) area of occupancy (iii) area, extent and/or quality of habitat (iv) number of locations or subpopulations (v) number of mature individuals. c. Extreme fluctuations in any of the following: (i) extent of occurrence (ii) area of occupancy (iii) number of locations or subpopulations (iv) number of mature individuals.

C. Population size estimated to number fewer than 2500 mature individuals and either: 1. An estimated continuing decline of at least 20% within five years or two generations, whichever is longer, (up to a maximum of 100 years in the future) OR 2. A continuing decline, observed, projected, or inferred, in numbers of mature individuals AND at least one of the following (a-b): (a) Population structure in the form of one of the following: (i) no subpopulation estimated to contain more than 250 mature individuals, OR (ii) at least 95% of mature individuals in one subpopulation. (b) Extreme fluctuations in number of mature individuals.

D. Population size estimated to number fewer than 250 mature individuals.

E. Quantitative analysis showing the probability of extinction in the wild is at least 20% within 20 years or five generations, whichever is the longer (up to a maximum of 100 years). VULNERABLE (VU) A taxon is Vulnerable when the best available evidence A taxon is Vulnerable indicates that it meets any of the following criteria (A to E), when the best available evidence indicates that it and it is therefore considered to be facing a high risk of meets any of the criteria A extinction in the wild:

4 to E for Vulnerable (see Section V), and it is A. Reduction in population size based on any of the therefore considered to be facing a high risk of following: extinction in the wild. 1. An observed, estimated, inferred or suspected population size reduction of 50% over the last 10 years or three generations, whichever is the longer, where the causes of the reduction are: clearly reversible AND understood AND ceased, based on (and specifying) any of the following: (a) direct observation (b) an index of abundance appropriate to the taxon (c) a decline in area of occupancy, extent of occurrence and/or quality of habitat (d) actual or potential levels of exploitation (e) the effects of introduced taxa, hybridization, pathogens, pollutants, competitors or parasites. 2. An observed, estimated, inferred or suspected population size reduction of 30% over the last 10 years or three generations, whichever is the longer, where the reduction or its causes may not have ceased OR may not be understood OR may not be reversible, based on (and specifying) any of (a) to (e) under A1. 3. A population size reduction of 30%, projected or suspected to be met within the next 10 years or three generations, whichever is the longer (up to a maximum of 100 years), based on (and specifying) any of (b) to (e) under A1. 4. An observed, estimated, inferred, projected or suspected population size reduction of 30% over any 10 year or three generation period, whichever is longer (up to a maximum of 100 years in the future), where the time period must include both the past and the future, and where the reduction or its causes may not have ceased OR may not be understood OR may not be reversible, based on (and specifying) any of (a) to (e) under A1.

B. Geographic range in the form of either B1 (extent of occurrence) OR B2 (area of occupancy) OR both: 1. Extent of occurrence estimated to be less than 20,000 km², and estimates indicating at least two of a-c: a. Severely fragmented or known to exist at no more than 10 locations. b. Continuing decline, observed, inferred or projected, in any of the following: (i) extent of occurrence (ii) area of occupancy (iii) area, extent and/or quality of habitat (iv) number of locations or subpopulations (v) number of mature individuals. c. Extreme fluctuations in any of the following:

5 (i) extent of occurrence (ii) area of occupancy (iii) number of locations or subpopulations (iv) number of mature individuals. 2. Area of occupancy estimated to be less than 2000 km², and estimates indicating at least two of a-c: a. Severely fragmented or known to exist at no more than 10 locations. b. Continuing decline, observed, inferred or projected, in any of the following: (i) extent of occurrence (ii) area of occupancy (iii) area, extent and/or quality of habitat (iv) number of locations or subpopulations (v) number of mature individuals. c. Extreme fluctuations in any of the following: (i) extent of occurrence (ii) area of occupancy (iii) number of locations or subpopulations (iv) number of mature individuals.

C. Population size estimated to number fewer than 10,000 mature individuals and either: 1. An estimated continuing decline of at least 10% within 10 years or three generations, whichever is longer, (up to a maximum of 100 years in the future) OR 2. A continuing decline, observed, projected, or inferred, in numbers of mature individuals AND at least one of the following (a-b): (a) Population structure in the form of one of the following: (i) no subpopulation estimated to contain more than 1000 mature individuals, OR (ii) all mature individuals are in one subpopulation. (b) Extreme fluctuations in number of mature individuals.

D. Population very small or restricted in the form of either of the following: 1. Population size estimated to number fewer than 1000 mature individuals. 2. Population with a very restricted area of occupancy (typically less than 20 km²) or number of locations (typically five or fewer) such that it is prone to the effects of human activities or stochastic events within a very short time period in an uncertain future, and is thus capable of becoming Critically Endangered or even Extinct in a very short time period.

E. Quantitative analysis showing the probability of extinction in the wild is at least 10% within 100 years

6