The following was received from Mike Carpenter of the US Fish & Wildlife Service as this Conservation Force Bulletin went to press. It will govern how the limited argali import permits will be allocated between US hunters who apply for permits:
“Each year, the Division of Management Authority (DMA), in consultation with the Division of Scientific Authority and other reviewing offices, makes a determination on the number of import permits that will be issued authorizing the importation of argali trophies from each of the three approved argali countries. Due to established criteria, it is not unusual that DMA issues fewer import permits than there are hunters booked to hunt in one of the three countries. To establish an equitable system for allocating the approved permits, we have established the following procedures:
“The US Fish and Wildlife Service, through the Division of Management Authority, will accept applications for the import of argali trophy (Application Form 3-200-21) between May 1 and May 15. All applications received during this two-week period will be given an application number (a PRT number) and grouped by country and, in the case of Mongolia, population. By group, application numbers will be drawn at random to create a numbered list of all applications received in each group (i.e., one list for Tajikistan, one for Kyrgyzistan, one for Mongolian gobi argali and one for Mongolian altai argali).
“Each year, we request and receive a list of approved hunters from the Governments of Tajikistan, Kyrgyzistan, and Mongolia. The “first-come, first-served” list from above will be cross-referenced to the lists of approved hunters. Starting with No. 1 on our list, we will go down our list, issuing permits to each hunter that appears on the approved hunter lists from the countries. Once we have reached the number of permits that we have determined could be issued for the year, we will hold all remaining applications until the end of the hunting seasons. Any cancellations and corrections will be chosen from the list by number.
“If needed, we will continue to assign numbers to applications after the two weeks, as they are received, in the unlikely event that these individuals will obtain permits in number order.”
Conservation News
Monuments to Desert Sheep: Conservation Force is happy to report that it is the primary fiduciary for two more important game monuments being created by renowned wildlife sculptor Rick Taylor. The sculpture project is entitled “Sons of the Desert” and has been commissioned by Organizacion Vida Silvestre A.C. (Mexico). Its purpose is to raise public awareness about the role of sportsmen in the revitalization of wild desert sheep populations and to celebrate the sheep and hunting that hunters value so highly.
There will be two monuments. One at the Mexico City Museum and the other at the Hermosillo Airport. Both will have interpretive and donor recognition plaques in both Spanish and English. The initial individual donors include Hubert Thummler, Jesus Yurén, Sergio Jimenez, Bill & Ingrid Poole, Todd Fry, Peter E. Seda, Christopher A. Dianda, Robert Robertson, Brian E. Drettmann, Alden B. Glidden, Everett C. Madson, Theodore H. Schutte, Alan M. Shearer, David A. Slikkers, Brenton L. Scott and Philip Repepi.
The project is being funded through tax deductible sponsorship contributions for limited-edition bronze maquettes at $3,900. Conservation Force receives a share of the proceeds for its sheep projects around the world.
For more information, or to make a contribution, contact Rick Taylor at: 250-353-7735 (www.ricktaylor.com).
USF&WS Proposal to Institute and Raise Inspection Fees: The USF&WS has announced that it will soon propose a graduated rise in the fees charged for all wildlife-related inspections at time of import and export. For the first time, they also are to apply to trophy hunters. The proposal includes a new “premium fee” for inspection of specimens of “protected species”. “A separate $19 premium fee will be charged for imports or exports of species protected under Federal law. Such wildlife includes federally listed endangered or threatened species, migratory birds, marine mammals, injurious species and wildlife protected under the Convention on International Trade in Endangered Species.” These premium fees will increase over the five years, rising from $19 in 2008 to $93 in 2012.
The Federal Register notice was not yet published as of this writing, but is to be published on Monday, February 25, 2008, and can be found at: http://www.gpoaccess.gov/fr/index.html. A public meeting is scheduled for April 3, 2008 in Room 200 of the USF&WS headquarters building at 4401 N. Fairfax Drive, Arlington, Virginia from 1 to 4 PM, but the “oral comments must be provided in writing.” Written comments must be received by April 25, 2008.
Conservation Force may not be able to issue another bulletin on this proposal before the April 25th comment deadline because the April issue will no doubt be devoted to the polar bear listing final rule. Rest assured, we will pass the information on to Don Causey for dissemination through his E-mail Extra Bulletin Service. Conservation Force will be filing a timely comment on behalf of itself and many of its 150 supporting organizations.
It is a felony criminal offense to fail to declare the import of any trophy or trophy part at time of import. As proposed, a base inspection fee will have to be paid (if undesignated port) and a separate “premium fee” for each species in any way governed by federal versus state law or regulation. The USF&WS claims the imposition of the fees on non-commercial imports and exports will “treat importers and exporters more equitably,” but we want to ensure it does not constitute a prohibitive tax on conservation-based trade and developing countries’ conservation strategies. In many instances it would also be excessive if indeed a separate “premium fee” were added for each separate species and specimen that falls under any federal law or regulation, i.e., is “federally protected.”
Misuse of Rhino Horn: The Professional Hunters Association of South Africa (PHASA) and Wildlife Ranching South Africa (WRSA) have taken the initiative to prevent and control the taking and export of white rhino horn for un-permitted purposes. They have called upon the Department of Environmental Affairs and Tourism of South Africa (DEAT) to take measures to prevent hunters from exporting white rhino horn for commercial purposes under the guise of being sport hunters taking a trophy for personal use.
This does not apply to typical tourist hunters such as Americans. US hunters are prohibited from making any commercial use of their trophies of hunted species. That is enforced under the Lacey Act.
Although the RSA white rhino has been downlisted to Appendix II of CITES because of its recovery status and management, it is an “annotated” downlisting for limited kinds of trade. Trade for commercial purposes is still prohibited as if Appendix I.
These alleged hunts call for strong action, not because there is any present risk to RSA rhino, but because of the potential implications for the favored treatment of hunting trophies of all CITES-listed game species. The issue was first raised during the last CITES Conference of the Parties. The hunting community is now aggressively taking steps to halt the rumored activity until proper CITES protocols are followed, such as downlisting without a limiting annotation or registered captive breeding that has been authorized by the Parties of CITES.
Democrats Dialogue with Hunting Community Leaders: The United States Senate Democratic Steering and Outreach Committee invited most of the hunting world’s conservation leaders to an early morning meeting on February 13, 2008 in the Mansfield Room of the Capitol.
The invitation was not transferable and was signed by Senator Debbie Stabenow who chaired the meeting; Senator Harry Reid, Senate Majority Leader; and Senator Blanche Lincoln, chair of Rural Outreach. Senators John Kerry, Barbara Boxer, Hillary Clinton and Ted Kennedy are named committee members, but did not attend. More than a dozen other Democratic Senators made appearances and statements including Amy Klobuchar, Thomas Carper, Ken Salazar, Ben Nelson, Jon Tester, Russel Feingold, Daniel Akaka, Mark Pryor, Sheldon Whitehorse, Richard Durbin, Tom Harkins and Jim Webb. Considering the hour of the morning and the fact that all federal employees were given a two-hour delay to appear at work because of the weather conditions, it was an impressive outreach to the hunting community by the Democratic Senate, no doubt about it. The invitation read, “It is our pleasure to invite you to join fellow leaders and experts for a discussion with our Senate colleagues on conservation issues affecting hunting, fishing and other outdoor sports and activities…. This meeting will provide an opportunity for us to exchange ideas about our common priorities for the 110th Congress as we work toward our shared goal of preserving our fish and wildlife habitats and outdoor heritage for current and future generations.”
The invitees were basically American Wildlife Conservation Partner (AWCP) members with the notable exceptions of the National Wildlife Federation and the AFL-CIO labor union. The AFL-CIO representative was Richard Tunka who said that the union’s membership (according to survey) was concerned about loss of habitat and access, and supported the Farm Bill (as did everyone, including the Senators). Nearly everyone, Senators and invitees alike, spoke. Steve Williams of Wildlife Management Institute and AWCP said that “conservation is bi-partisan.” Dave Nomsen, the new chair of the AWCP, introduced the Century 21 booklet of the AWCP. Bob Model of Boone & Crockett led off and turned the heads of the Senators with the age and history of Boone & Crockett. Bob also introduced the President’s Executive Order and related plans. (There are three planning meetings and the final conference is expected to be next September. I cannot say enough about Bob and the Boone & Crockett Club. They spearheaded the formation of the AWCP and played a key role in inspiring the Executive Order.)
Everyone supported the Farm Bill and some thought that CRP would be reduced from 38 million acres to 32 for unavoidable technical reasons. I was the only speaker to address international concerns and did so by first educating the Senators on the role of hunting and fishing in the United States. I certainly had their undivided attention and convincing looks of sympathy and concern. My presentation went something like this: The name Conservation Force stands for the fact that “sportsmen are the force”. 147 million living Americans have hunted or fished. Perhaps a minority, but significant. They pay more for conservation than all others combined. More for law enforcement, more for research, more for habitat, more for management, etc. It is in the billions of dollars each year in direct support of our conservation infrastructure. I repeat: more than everyone else in society combined. Our system is famous for using recreational hunting and fishing as the foremost “tool” for conservation. Conservation Force and its 150 allied partners have projects in more than 30 foreign nations. Our concern is with US laws and regulations that prevent and obstruct the use of hunting as “a tool” for conservation overseas. The foremost tool for conservation here at home can’t be used overseas. For example, one Congresswoman this last year instructed that hunting not be used as “a tool” for conservation overseas…. Thank you so much for the opportunity to work together for the common good.
The chairman, Senator Debbie Stabenow, said that this was only the first meeting and she hoped to have more and to work together in the future. (She then searched our faces.) Obviously, the AWCP forum is serving the hunting community well, as intended.
Sheep-Force Argali Program: Conservation Force has had a long-term commitment to conserving argali and perpetuating argali hunting. In 2008 we are renewing and re-initiating those efforts with additional partners and resolve. Tentatively, this new program is to be called Sheep-Force. It will be operated as a program, not just a project of Conservation Force, for it will cover at least five different countries and multiple species of sheep and mountain species.
One of the first steps was to file an up-to-date Freedom of Information Act request to the USF&WS’s International Division for a copy of their internal determinations underlying argali trophy imports over the past three years (2005, 2006 and 2007) from Mongolia, Tajikistan and the Kyrgyz Republic (Kyrgyz, Kyrgyzia and Kyrgyzstan). We filed the FOIA request in November, but did not receive the data until mid-February. There are two separate determinations made by separate parts of the Division of Management Authority (DMA) for each of the three countries. An Enhancement Evaluation is made by Senior Biologist Mike Carpenter each year for each country. It analyzes all available data, confirms whether or not the respective country’s argali quota is supportable and, most importantly, determines whether or not the imports that are biologically supportable “will provide enhancement to the species and its habitat” in that respective country.
A separate Intra-Service Section 7 Biological Evaluation Form is completed by the Division of Management Authority with the separate written concurrence of the Chief of the Branch of Permits of Division of Management Authority and the Chief of the Branch of Consultation & Monitoring of the Division of Scientific Authority. They make a finding of the likelihood that the hunting will adversely affect the species which includes a review of the quota and its reduction to reduce the risk of possible adverse effects. That is three different biologists in two different divisions.
We originally requested the up-to-date determinations from the USF&WS to use at a meeting Conservation Force was invited to with the Mongolian authorities and WWF concerning the management of Mongolian argali. Readers may remember that Conservation Force successfully provided the legal representation of Mongolia in the suit the antis filed but lost to stop the importation of argali trophies several years ago. Because of that, we held the attention of the Mongolian officials at the meeting, but did not receive the FOIA return in time to use it there to give them a better understanding of the process and ability to deal with it. The materials have been forwarded on to WWF for Mongolia’s benefit since that meeting.
One thing that can be gleaned from the 68 pages of documents is the formula that is used by the Service to decide the number of imports it will allow. The Service does not allow the import of more than 2% of the estimated population and reduces that by a number equal to twice the legal quota established by the foreign wildlife authorities. An example is Mongolia in the 2006/2007 season. The estimated total population was more than 13,000, so the sustainable take of 2% was 260 animals. Mongolia’s quota was 60, so the Service deducted 140 to 150 animals estimated to be poached from the 260, leaving a balance of 110, thus concluding that the quota of 60 was within conservative range. The Service accepted the full number of Gobi permits Mongolia intended, 45, but not the number of Altai permits desired, 25. Because of specific issues with the Altai populations, the Service has limited that restricted area to 10 imports per year, at least until that area’s population is better known and verified.
Of some concern to us is the report that the Mongolian “Ministry indicates that they intend to conduct surveys of both Altai and Gobi populations beginning in July, 2008. That is the wrong time of the year to locate argali that can be expected to be widely dispersed. One has to wonder about the motive of surveying them when they can’t be found. We don’t know if such a survey was commenced, but do know it will not be comparable to earlier surveys in November. Regardless, Sheep-Force is intending greater participation itself to help take surveys that will be successful and be repeatable.
The promising news is that there is no apparent decrease in horn size for the better part of a decade in the three countries, all three countries are reported to now have management plans, most populations are stable or increasing, a great deal of habitat has been set aside for protection and the quotas are generally conservative. – John J. Jackson, III.
