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.
