USGS

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U.S.G.S. - Patuxent Wildlife Research Center
Bird Banding Laboratory
12100 Beech Forest Road
Laurel, MD 20708-4037
May 19, 2000

Dear Bander:

This is the third of three letters communicating decisions and plans stemming from the review of the North American bird banding program. In our first letter (September 24, 1998), we mentioned the availability of the Review Panel’s final report and recommendations (The North American Bird Banding Program: Into the 21st Century - available at http://www.pwrc.usgs.gov/bbl/resources/nabbpcvr.htm), and we described the process for moving from the Review Panel’s recommendations to decisions and actions in the bird banding program. Briefly, in that process, an interagency Implementation Team was established to guide improvements to the banding program and operations of the Bird Banding Laboratory (BBL). The Implementation Team identified six priority areas in which to focus efforts, and then appointed Task Forces to refine panel recommendations in these areas, and to develop specific plans for implementation. The Implementation Team considered Task Force recommendations relative to the Review Panel’s report, and agency needs, policies and resources, and then made final decisions for BBL to implement and communicate to banders.

In our first letter, we communicated new policy and procedures for Data Release. In the second letter (January 6, 1999) we communicated results for priority areas Electronic Data Management, Location Data, and Ancillary Data. Copies of our first and second letters are available through our web site at the above address. This letter, our third and last one, covers priority areas Recapture/Resighting Data, and Permit Policies and Procedures. The latter area is of considerable scope and import, where decisions of the Implementation Team have resulted in significant changes. Because the amount of material to be covered is lengthy, we have chosen to present it as two appendices to this letter.

Thank you in advance for considering these new developments. We look forward to working with you in our continuing effort to improve operations of the BBL and the broader North American bird banding program. We solicit your comments and suggestions about how to make these various changes as convenient as possible for the bander to adapt to.

Sincerely,

John Tautin,

Chief, Bird Banding Laboratory

APPENDIX I. RECAPTURE/RESIGHTING DATA

BBL will develop a bird banding recapture/resighting database for use in contemporary and future migratory bird conservation. A “recapture” is the capture of a previously banded bird. A “resighting” is the observation of a bird previously marked with a unique identifier such as a neck collar, wing tag, or radio transmitter. Recaptures and resightings are usually made by the original bander, but may be made by other banders, collaborators or the public. Recaptures and resightings constitute the majority of post-release data obtained from banded nongame birds, and for most analytical purposes the two can be considered equivalent. Individual banders often make extensive use of their own recapture and resighting data. However, for various reasons no longer valid, most recapture and resighting data historically were not included in the BBL database and, consequently, have not been available to others for analysis.

Today, the value of recapture/resighting data is widely recognized in light of the need for more and better data to support avian research and management. Advances in computer technology now make it feasible to manage the large volumes of recapture/resighting data. A suite of powerful analytical models and software is available for analyzing them to estimate survival rate, population size and rate of change, movement probabilities, age-specific breeding probabilities, and parameters reflecting contributions of demographic components to population growth. The results can be applied to studies of population ecology, evolutionary ecology, landscape ecology, and behavioral ecology, as well as to monitoring programs.

The coming together of data needs, computing power, analytical tools, and applications for results make development of a recapture/resighting database at BBL timely and useful. To accomplish this development, BBL must design a database structure; develop record formats and data edits, develop ways for the data to be received and disseminated electronically via the Internet; and integrate the new database into its vast existing databases and re-engineered computer system. Data sets appropriate for inclusion in the database must be identified and obtained. Project profiles describing how individual data sets were collected must be developed. The development of a recapture/resighting database will occur during 2000 with the support of a contract biologist recently hired to work at BBL.

Some banders who already have good recapture data may be invited this year to contribute them for “beta testing” of the new database. Eventually, depending on need, feasibility, and success of our initial development, banders may be asked to submit recapture data on a regular basis along with their banding data. BAND MANGER has been programmed in anticipation of this possibility. BBL will keep banders informed as our new recapture/resighting database develops. BBL looks forward to working with banders in this exciting endeavor that will enhance the quality and quantity of banding data available for the conservation of migratory birds.

APPENDIX II. PERMIT POLICIES AND PROCEDURES

Permit Policies and Procedures are very important to banders, because permits provide the enabling authority for banders to carry out their work. Permit Policies and Procedures also provide protections for birds being studied, and the means for banding offices to balance resources available to them with support they are able to give banders. In making its decisions regarding Permit Policies and Procedures, the Implementation Team was of the opinion that two general issues cross-cut a number of the specific recommendations: (1) the need for fewer and simpler procedures in the permitting process; and (2) the need for maximum objectivity in all decision-making that impinges upon banding clients. The Team also stressed the importance of allowing opportunity for comment by the banding public on all discretionary policy recommendations, before they become final. If [comments invited] appears next to a topic heading in this document, banders are invited to submit comments to the Chief, Bird Banding Laboratory, USGS Patuxent Wildlife Research Center, 12100 Beech Forest Road, Laurel, MD 20708-4037 (John_Tautin@usgs.gov).

A. Roles of the U.S. Geological Survey and the U.S. Fish and Wildlife Service

The 1993 transfer of BBL from a management agency with regulatory responsibilities (the US Fish and Wildlife Service (FWS)) to a research agency (the National Biological Service, and later the US Geological Survey (USGS)) created uncertainties about the roles, authorities and responsibilities regarding bird banding and bird banding permits. The Implementation Team made certain decisions aimed at defining these roles and responsibilities of the respective agencies.

  1. USGS (BBL) will retain full responsibility for issue and management (including review, renewal, and revocation) of bird-banding permits, but will consult with FWS’ Office of Migratory Bird Management (MBMO) in advance of any such actions that could have practical implications for the FWS. This liaison function will be codified in an existing agreement between USGS and FWS.

  2. FWS, not BBL, has responsibility for enforcing the Migratory Bird Treaty Act as it relates to the banding of birds. FWS will maintain full responsibility for issuing Special Use Permits, Collection Permits, Salvage Permits, Endangered Species Permits and other migratory bird permits. If BBL becomes aware of an allegation of unauthorized use of bands on migratory birds, BBL will notify the appropriate FWS authorities of the alleged violation. BBL will take no further actions unless requested by FWS.

  3. The salvage provision of bird banding permits will be modified and limited to reflect FWS’ pre-eminent responsibility for regulating salvage of birds (See H).

  4. Roles and responsibilities of the BBL and FWS will be clarified as needed through amendment of language in Title 50 Code of Federal Regulations-Wildlife and Fisheries (50 CFR).

B. Types of Banding Permits [Comments invited]

  1. Master Permits are issued to individuals (personal permit) or institutions (station permit with designated responsible individual) who are responsible for all banding carried out under the permit, and who may supervise Subpermittees.

  2. Subpermits are issued to individuals authorized to band under the supervision of a Master permittee, subject to the terms of the Master’s permit.

  3. The Conservation Agency Letter of Authorization (Bird Banding Manual page 2-3), which gave blanket authority to State and Federal agencies to have employees and cooperators band without obtaining BBL approval, will be eliminated. Persons formerly banding under Conservation Agency Letters of Authorization will band as Subpermittees and require approval by BBL. This will eliminate the often confusing functional distinction between Subpermits and the Conservation Agency Letter of Authorization, and it will enable a more uniform and fair permitting process, and help assure that all banders meet qualifications standards.

C. Criteria for Issuing Master Banding Permits [Comments invited]

  1. Qualifications: Whether applying for a personal permit or as the responsible individual for a station permit, applicants for Master banding permits must provide clear evidence of competent banding skills. Preferably, but not necessarily, this evidence will be certification at the Permittee level by the North American Bird Banding Council (NABC), a partner organization representing ornithological organizations and associations whose members use banding as a tool in their work. (See http://www.nmnh.si.edu/birdnet/nabc) [new link added 8/04 http://www.nabanding.net/nabanding/]. Applicants for master permits who are not NABC-certified must provide evidence that they meet or exceed the level of experience required for NABC certification. Applicants seeking a permit strictly for educational purposes must be certified at the more rigorous Trainer level by the NABC, or provide evidence that they meet or exceed the level of experience required for NABC certification at the Trainer level. BBL will develop a Memorandum of Understanding with NABC and work with NABC to develop and publicize clear qualifications standards for banders. These standards will apply equally to applicants for new permits and holders of existing permits, and to both personal and station permits, i.e., individuals responsible for station permits must meet the same qualification standards as holders of personal permits.

  2. Purpose: Applicants for new or renewing (See L). Master banding permits must include a coherent project proposal that describes the purpose and scope of the banding, and how their specific objectives are best accomplished through study of individually marked, wild birds. The "purpose" section will include an explanation of how the banding will advance avian biology, avian conservation, avian conservation education, or avian management. The "scope" section will include a definitive list of bird species or species groups that will be banded, the means of capture, the size(s) and types of bands required, a description of auxiliary markers requested and the marking scheme proposed, an estimate of the number of banded birds of each species required for each year of the project, and the time frame necessary to answer the question(s) posed. The permit will be issued only for the banding project specifically described in the proposal. To be approved, projects must have defined biological, conservation, conservation education, or management objectives dependent on banding and achievable through the procedures proposed and with the minimal scope necessary to achieve the stated objectives.

  3. Conservation Impact: Applicants for master banding permits must include an evaluation and statement of the potential impact of the project on birds and their populations. For approval, the project proposed must not pose an unusual or unacceptable level of risk to the welfare of the population(s) under study. In questionable cases, the BBL will consult with the FWS' MBMO before making such a determination. Banding projects will not be required to have formal Animal Care and Use Committee approvals, but all banding must comply with the principles, spirit and intent of the Animal Welfare Act of 1970 (see J).

  4. Administrative Burden: Applicants for master banding permits must include information sufficient to enable the BBL to assess the administrative burden associated with managing the banding project proposed. To be approved, the project proposed should not impose an excessive level of administrative cost on the BBL relative to the importance of the project. In the event of such a determination, the BBL will contact the applicant, explain the concern, and attempt to negotiate a modified proposal that would be administratively cost-effective. The BBL will develop a set of criteria for administrative tolerance and include these as guidelines in the application package.

D. Criteria for Issuing Subpermits [Comments invited]

  1. Master permittees may have Subpermittees who band within the scope of the Master's banding authorization.

  2. Subpermittees must meet the same NABC based qualification standards as Master permittees (see C.1), and the project(s) they work on must meet the same requirements for purpose, conservation impact, and administrative burden required of the Master, unless the Subpermittee's work is sufficiently limited to warrant exception. For example, a Subpermittee new to banding and working on a single, tractable species would not be expected to have the qualifications of one who might operate a large-scale, multiple species project. Master permittees are responsible for arranging any necessary training and assuring that their Subpermittees meet qualification standards. Subpermittees may band without direct supervision if so authorized by the Master Permittee.

  3. Master permittees must submit the names of Subpermittee applicants to BBL as they are designated, along with evidence of qualifications and a project description (including, purpose, conservation impact, and administrative burden), if different from that on which the Master's own permit is based. If approved, the Master's permit will be amended accordingly to list the Subpermittee and cover her/his project.

  4. If BBL finds deficiencies in the proposal or the potential Subpermittee's qualifications, BBL will promptly notify the Master permittee of the unacceptability and confer on methods of resolution. The potential Subpermittee will not be permitted to band until the proposal and/or qualifications are deemed acceptable by BBL. Once Subpermittees are approved by BBL, Master permittees are free to communicate authorization to their Subpermittees and manage them in whatever manner is most convenient. BBL will no longer actually issue subpermits, per se. Instead, while engaged in banding, the Subpermittee must carry a copy of the Master's permit which documents the Subpermittee's authorization to band.

  5. Birds banded by Subpermittees are reported by the Master permittee on her/his own banding schedules. The Master bears full responsibility for the distribution of bands to Subpermittees and for accuracy of the Subpermittees' records.

E. Species Designations on Banding Permits [Comments invited]

  1. To better manage authorized banding activities and economize band management, the activities authorized on banding permits will become more specific. BBL permits will follow the Canadian Bird Banding Office's (BBO) model for permits, which indicates species, species groups, or projects on the banding permit, adding additional groups as necessary. Species or species groups listed on the permit will be limited to those specified in the bander's approved projects. In some cases, permits may be project specific, e.g., "Monitoring Avian Productivity and Survivorship (MAPS) banding only". Bands issued will be limited to sizes and quantities necessary to carry out the project. The objective is to make permits and bands issued consistent with approved projects.

  2. Authorization to band certain sensitive species, e.g. hummingbirds, may require special qualifications that will be made explicit by the BBL in cooperation with NABC. Therefore, a permit allowing banding of, say, breeding birds of eastern deciduous forests, will state certain exceptions, e.g., hummingbirds, if the special qualifications for those species are not met.

  3. Applicants, or already permitted banders, wishing to band rehabilitated birds must meet the same criteria as for any other banding project.

F. Auxiliary Marking Authorizations [Comments invited]

Auxiliary marking will be authorized on the master permit proper, and not as a separate permit. Marking authorizations will ensure compatibility with different marking schemes. BBL will maintain a database of authorizations and require that banders coordinate with others using similar schemes.

G. Special Equipment Authorizations [Comments invited]

Capture techniques such as mist nets, rocket nets and chemical agents, which require special training to use, will continue to be specified on permits when authorized. If such techniques require pre-authorization from other agencies, the applicant will be so informed and the restriction noted on the permit letter. Feather and blood sampling will also require special authorization from BBL, but not from other agencies.

H. The Salvage Provision of Federal Bird Banding Permits

  1. The bird-banding permit will authorize banders to salvage birds that may die during a banding operation, but not to salvage birds from other sources such as road kills. This significant change in policy emphasizes the banding authority of a banding permit and de-emphasizes the salvage authority, which was often misunderstood and sometimes abused. 50 CFR will be amended to reflect the policy change, and the official name of a bird banding permit will be changed from "Federal Bird Marking and Salvage Permit" to "Federal Bird Banding Permit". Although the reference to "salvage" in the name of the bird banding permit will be deleted, the salvage authority (and its limits) will be stated on the permit. Banders may hold birds salvaged during banding operations for up to six months. After that, requirements for management of birds salvaged under a bird banding permit will be identical to those of the FWS Salvage Permit, i.e., the birds must be reposited in an FWS authorized collection. Banders wishing to salvage birds obtained by means other than their banding operation must obtain a FWS' Salvage Permit.

  2. Salvage of birds from banding operations should be rare events.

  3. Banders will not be permitted to retain their banding permits strictly for the purpose of salvage of dead birds.

I. Waterfowl (Game Bird) Banding [Comments invited]

  1. Permits may be issued to any qualified applicant for banding waterfowl or other migratory game birds. In such cases, the BBL will forward applications for migratory game bird banding permits to the FWS' MBMO to review for any possible conflicts with Federal population management programs. In the event of a potential conflict, the BBL will advise the applicant on appropriate coordination that must be made.

  2. State and Federal agencies will be authorized to band by BBL in the same manner as individuals, research institutions and universities (See D). The Conservation Agency Letter of Authorization presently used by State and Federal agencies to "deputize" banders will be discontinued (See B.3). State and Federal agency-sponsored waterfowl banders will fall under the Subpermittee rules outlined in Section D. In addition to effecting a more uniform and fair permitting process, this new policy should also result in a higher standard for participation in waterfowl banding programs.

J. Animal Care and Welfare Responsibilities

Banding projects will not be required to have formal Animal Care and Use Committee approvals, but all banding must comply with the principles, spirit and intent of the Animal Welfare Act of 1970 (P.L. 91-579) and its amendments (P.L. 94-279, even though the Act presently excludes birds and most field studies. Banders must also band in accordance with the high ethical standards of animal use and care reflected in guiding documents from the NABC and The Ornithological Council (OC). For details and expectations, refer to (http://www.nabanding.net/nabanding/) and the OC's 1997 GUIDELINES FOR THE USE OF WILD BIRDS IN RESEARCH by A. S. Gaunt, et al. The burden of ethical and legal compliance with these animal welfare standards will be on the bander.

K. Criteria for Issue and Return of Bands [Comments invited]

BBL is developing a new, electronic band management system for issue, inventory and return of bands. The intent of the system is to track more precisely what bands have been issued to banders. This will help assure that bands are issued consistent with species or groups authorized on the bander's permit, and that banders use and report previously issued bands before being issued significant quantities of new ones. The new system will also facilitate the reintegration of returned bands into the inventory. When bands are no longer needed, either due to completion of the project, or inactivation of the permit, unused bands will be returned to BBL for accounting and possible reissue to other banders.

L. Banding Permit Renewals and Reporting [Comments invited]

  1. Banders will be required to apply for renewal and furnish a report on permitted activities. (The format of the report has yet to be developed). Applications for renewals will be subject to the same requirements as original applications (See C.2,C.3,C.4). Both existing and future permittees shall meet the same standards for renewal and reporting.

  2. The current two year renewal cycle will be extended to four years. Banders will be reminded six months before the expiration of their permits that they must reapply if renewal is desired.

  3. All "valid-until-revoked" permits, which now typically are issued to State and Federal conservation agencies, will be converted to regular permits and be subject to a standard review and renewal cycle.

M. Permit Suspension and Revocation [Comments invited]

  1. BBL will retain the right to amend, suspend or revoke banding permits for just cause. BBL will consult with BBO, NABC and OC to develop firm, clear, written criteria for amending, suspending or revoking banding permits. Examples of conditions that might trigger amendment, suspension or revocation might include failure to submit banding records, violation of Federal or State laws and regulations pertaining to migratory birds, and failure to band in accordance with animal welfare and care guidelines. 50 CFR will be updated to reflect the criteria for amending, suspending or revoking banding permits.

  2. Violations by Subpermittees will be considered violations by the Master permittee under whom the Subpermittee bands.

N. Banding Permit Appeal Procedures

  1. The Director, USGS Patuxent Wildlife Research Center, will be the first level of appeal for adverse BBL permit actions (denials, suspensions, revocations). The Chief Biologist, USGS Biological Resources Division, will be the final level of appeal.

  2. The relevant regulations in 50 CFR will be changed to reflect the appeal process.

O. Tax Vouchers

The BBL will not vouch for expenses itemized by banders for income tax deductions, but BBL will, on request from a bander, verify the permit and provide a summary of bandings submitted during the tax year.

P. Web Access to Banding Permit Documents [Comments invited]

Permit application forms and all documents included or referred to (e.g. animal welfare guidelines) in the banding application package will be made available through the BBL home page.

Q. Summary

Several significant changes are included among the Permit Policies and Procedures established by the Implementation Team, to be effected by BBL:

R. Implementation schedule

The new Permit Policies and Procedures will be implemented gradually as BBL operations are "re-engineered" and capabilities for implementing changes develop. Some changes will be effected immediately, e.g., greater consideration for animal care and welfare. Some changes will be effected as soon as details can be communicated to banders, e.g., adoption of NABC standards for bander qualifications. Some changes, e.g., the link between band issue and permit authorizations, will not occur until BBL's new computer system is ready in early 2001.