First of all, I was surprised to notice that the Notification did not make any reference to a transaction that has apparently, if my information is correct, taken place by the end of last year, between the Philippines and Qatar and which concerned not less than four Spix’s macaws. It is probably that transaction that incited Brazil to ask for the issue of the Notification, as it appears that Brazil has expressed serious concern about the issue rather recently.

Secondly, I was also a bit surprised that the Secretariat did not choose either to make comments regarding the request of Brazil or to support Brazil in its attempt, e.g. in urging the Parties to follow the request of Brazil expressed in paragraph 6 of the Notification.

I believe the Secretariat was informed of the above-mentioned transaction but I wonder whether it was informed before it took place, as it should have been, if not in accordance with Resolution Conf. 9.5, at least in accordance with Resolution Conf. 11.14, paragraph b) under AGREES, insofar as an comparable import permit was issued by the competent authority of Qatar, which was not yet a Party to CITES at the time of the transaction. If the Secretariat has not been consulted before the transaction took place, as I suppose, I wonder what it has done after having been informed, because it appears obvious that the transaction was contrary to Resolution Conf. 11.14, considering the definition it contains of the term "bred in captivity for commercial purposes" and the fact that the exporting operation is not included in the Secretariat Register for the species in question. The transaction was most likely also contrary to Resolution Conf. 10.16 (Rev.), since the breeding stock of the operation was almost certainly established on the basis of birds illegally exported from Brazil, the only range State of Spix’s macaws. I understand that the Parties are not automatically bound by Resolutions but it is the role of the Secretariat to urge the Parties to implement them.

In addition, several years ago, if my souvenirs are correct, the Secretariat exchanged correspondence with the Management Authority of the Philippines and expressed its opinion about the status of the exporting operation and recommended that no export of captive-bred birds of Appendix-I species, except of that registered (Aratinga guarouba) be authorized until these species have been registered also. Has the position of the Secretariat changed since then? This I do not know.

Finally, if the Secretariat is not a member of the Permanent Committee for the Recovery of the Spix’s Macaw, it was invited to participate in its meetings and was informed of its objectives and actions. The Secretariat knew also the involvement of the Philippines operation since it facilitated at least one transaction in the past made by the operation within the framework of the Committee activities. I think therefore that the Secretariat should be very concerned by the transaction that took place last year, should firmly condemn it, should try to avoid that similar transactions took place in the future and, perhaps, should take steps to favour one way or another the involvement of the importer in Qatar in the Brazilian management plan, now that Qatar has joined CITES. The conservation of the Spix’s macaw, even in captivity only, should be, in my opinion, a challenge for CITES as a whole and the Secretariat in particular.

I would appreciate receiving your comments on the above remarks.