Comments to the U.S. Fish and Wildlife Service on Applications to Conduct Certain Otherwise Prohibited Activities Under the Endangered Species Act within the Captive Bred Regulations
Although the captive breeding wildlife (CBW) registration system was established to facilitate the captive breeding of endangered and threatened species in order to enhance the conservation of the species in the wild, the vast majority of CBW registrants breed species in captivity with no intent to ever reintroduce any of their animals into the wild. Instead, in an attempt to meet the “conservation” requirement for obtaining or renewing a CBW registration, they make donations to in-situ conservation programs. It is entirely unknown, however, if these programs are legitimate and, other than accepting information submitted by the applicant that he/she supports such programs financially, it would appear that neither the applicant nor the FWS engages in any objective assessment of the legitimacy or effectiveness of the in-situ conservation program.