Comments below, crafted by AU Lobbyist, Greg Smith, were submitted on behalf of the AU in response to the U.S.P.S. proposed amendment to regulations regarding shipping of live animals. This is another effort by the AU to protect the right to ship and maintain reasonable cost.
American Racing Pigeon Union
Comments on Proposed New Mailing Standards
for Live Animals and Special Handling
as of May 24, 2013
The American Racing Pigeon Union (AU) is a non-profit organization with 700 affiliated clubs around the United States and approximately 10,000 members. Founded in 1909 from the merger of homing pigeon associations established in the 1800’s, it is the largest organization in the United States dedicated to the sport of pigeon racing. As stated in the AU Constitution, the AU “exists to promote, protect, and enhance the sport of racing homing pigeons, to cooperate with other organizations, which directly or indirectly accomplish those goals, and to provide services and benefits to its members.” The AU and its membership also prides itself on being at the forefront of promoting ethical standards and practices to assure the well-being of the birds, compliance with all federal and state laws, and the advancement of this family-friendly hobby.
In 1985, the United States Postal Service (USPS) approved the express mail shipping of pigeons in the United States. This service has been a significant benefit to the members in that it allows for safe and secure overnight shipping of birds at affordable rates. Over the years, AU has worked closely with the USPS to ensure that affordable shipping remains available to our members. This goal is vital to the AU mission and to the sport of pigeon racing as a whole. Although the sport has an intensely loyal following, its participants, as a general rule, are people of limited means. Without the ability to use the Postal Service, they simply would not be able to participate in races or send or secure birds for breeding and other purposes. Accordingly, without affordable access to the mail, the sport of racing pigeons could be virtually eliminated.
Unfortunately, the average cost to ship racing pigeons has already doubled in recent years. Though the cost depends largely on the point of origin and destination, and of course the number of birds to be shipped, in 2006 the average cost to ship two birds was approximately $18. Presently, the average cost is between $36 and $40. For the average $36 shipment, then, the proposed new mandatory special handling service fee, assuming the lowest $9 rate, would represent an additional 25% increase in cost. We do not believe that yet another rate increase, especially an increase so large in proportion to the current cost of shipment, is warranted at this time – particularly when the USPS is not proposing that any additional service (which would not be necessary) would accompany the rate increase.
In the preamble to its Proposed Rule, the USPS lists various reasons why the Postal Service must treat shipments containing live animals differently than ordinary mailpieces, thus presumably increasing the expense to the USPS and justifying the proposed mandatory service fee. AU members are devoted to the health, safety, and welfare of racing pigeons in transport and support the USPS in instituting sufficient standards to ensure the safety of racing pigeons, USPS employees, and the general public. However, many of the circumstances cited by the USPS do not apply to racing pigeons, or apply to a much lesser extent than other live animals or birds that may be transported by the USPS. The USPS is therefore unlikely to incur the full cost of special handling service in transporting racing pigeons in particular. Since those costs will not be incurred by the USPS, it would be unfair to impose them on racing pigeon fanciers.
First, the shipping of live racing pigeons poses no meaningful threat to the health and safety of Postal Service employees or the general public resulting from disease. Although little known, racing pigeons are not the same as pigeons commonly seen congregating in city parks. Rather, they are thoroughbreds much like racing horses and are highly prized for their athletic ability. As such, their bloodlines are closely tracked, they are fed careful diets, and they are kept on a strict sanitary and medical regimen. Within the avian community, racing pigeon fanciers are highly regarded for the standards of health they have for their birds. Interestingly, there are a number of veterinarians in the United States who specialize in racing pigeon medical treatment. Any racing pigeons transported through the Postal Service are therefore highly unlikely to be diseased.
Even more to the point, Pigeons have no vectors for disease in common with humans; in other words, "Pigeon parasites cannot and do not live on or in humans, and vice versa." See Homing Pigeons: Perception vs. Reality, by the Avian Assistance Council [available through the American Racing Pigeon Union]. Because pigeons have a much higher body temperature than that of humans (around 107 degrees), as a rule disease is not communicable between pigeons and humans. This makes pigeons safer than many animals commonly in contact with humans, such as dogs and cats, in terms of the spread of disease. Thus, the AU is confident that the shipping of racing pigeons through the USPS does not pose a threat to Postal Service employees or the public due to diseased animals. Indeed, despite many thousands of shipments, we have never heard of any postal worker being adversely affected by handling of racing pigeons.
Second, there are no "offensive odors or noise" associated with the transportation of racing pigeons. Pigeons themselves have no odor. Also, pigeons make a soft cooing noise, much like a dove's coo with which most people are more familiar. In 1995, an environmental testing firm conducted a noise survey of pigeon lofts near Oklahoma City. See Homing Pigeons: Perception vs. Reality, by the Avian Assistance Council. This study found that inside lofts with 100 to 600 pigeons, the noise level was equivalent to, or lower than, simple conversational speech measured in decibels. The study also found that, from 25 feet away, a loft with 100 pigeons contributed 10 decibels or less – about the same as the soft rustle of leaves – to the existing background noise. That contribution was insignificant considering the nearly 50 decibels of daytime background noise from other sources measured at the same location when the pigeons were removed from the loft.
Finally, while the well-being of racing pigeons is of the utmost concern to racing pigeon fanciers and certain precautions in shipping are warranted and necessary, racing pigeons are also extraordinarily hardy animals. For example, racing pigeons have been used by U.S. Forces in the Gulf because of their hardiness as backups to mechanical bio-chemical sensors. There are active racing lofts from the deserts of Arizona to the tundra of Alaska, where pigeons thrive under varying conditions. Accordingly, racing pigeons impose a much lesser burden on shipping carriers than other live animals might with regard to taking into account temperature and weather conditions in transit. Further, the USPS already imposes restrictions on temperature and location in order to ensure that environmental conditions do not threaten the health and safety of live birds during transport. Shippers utilize specially designed mailers that are approved by the United States Department of Agriculture, the USPS, and the International Air Transport Association. Given the restrictions and protections already in place, we do not believe the USPS will incur any significant additional costs in accounting for weather conditions as a result of transporting racing pigeons.
Because the shipping of racing pigeons is very unlikely to cause the USPS to incur anywhere near the full range of expenses that may otherwise be associated with special handling service, and because the cost of paying the full fee for such service may be prohibitively expensive for most AU members, AU opposes the imposition of a new, mandatory special handling service fee on the shipment of racing pigeons. Notably, the AU worked closely with Fed Ex with regard to shipping standards for racing pigeons when Fed Ex secured its contract to ship postal service mail. Fed Ex was very satisfied that it could ship the birds safely and efficiently while also holding costs down. We therefore believe the imposition of the new mandatory fee is unnecessary.