The US Fish & Wildlife Service (USFWS) finally issued Zambia elephant import permits in late October. The Division of Scientific Authority made the necessary “non-detriment” finding in March, and the Division of Management Authority made its enhancement finding in late October after the hunting season was almost wrapped up. The USFWS said it would have issued permits for 2010 as well as for 2011, but no one submitted applications for last year. Any US hunter who took an elephant in 2010 can and should now submit an import permit application. Conservation Force assists hunters as a free public service with initial permitting, but we only submitted permits for 2011.
The issuance of permits came at the very end of the season, too late for the hunters who had applied. Although no applicants received permits before going on safari, a few hunters chanced it and took elephants in anticipation that permits would be granted after their hunts. Others did not because paying for an elephant hunt “on-the-come” without an import license is a proven substantial risk due to USFWS’ change in practice. Those who took the risk were also counting on the likelihood that Zambia’s elephant will be downlisted at the next CITES CoP; CoP16 in March of 2013.
I will not repeat the long, sordid history behind this approval. The agency promised these permits before the season started, but permits were not forthcoming. We had been working for weeks on a new suit, Zambia II, when the news reached us. Suit was to be filed the very week USFWS finally responded to our many requests and Freedom of Information Act requests for an update as 2011 clicked past.
Importantly, USFWS has approved only permits for 2010 and 2011. It pointedly said that it must make another non-detriment and enhancement finding before issuing permits for 2012 and beyond. Rest assured, we are working hard to identify and address all remaining issues. We also expect that Zambia’s elephant will be downlisted in 2013 at the 16th Conference of the CITES Parties in Thailand. It missed downlisting by only a few votes at CoP15. Even the US voted for the downlisting and made a floor speech in favor of the proposal. In that event, the trophies taken since hunting opened in 2005 will be importable. In the meantime, Conservation Force’s first Zambia suit for import of elephant taken before 2010 will be on appeal. The appeal briefing will be complete and orally argued this Spring, 2012. There was more proof of the status and benefits after the last CITES CoP (proof Conservation Force helped contract the research to produce) but USFWS is not relating it back to elephants taken before 2010. Nothing was different about the non-detriment and enhancement of those earlier elephant except the finding of USFWS. The Zambia program was the same, and the populations were stable or increasing, as the surveys show.
The elephant hunting is restricted by Zambia to three (3) communal areas and is intended to reduce human-elephant conflict. The quota is limited to 20 elephant. The Panel of Experts at the last CITES CoP issued an opinion that Zambia could support a quota of 130 elephant per year or more, which Zambia was going to limit itself to if its elephant were downlisted. The Division of Scientific Authority of USFWS placed a great deal of weight on that report in making its non-detriment determination. Up to that time, USFWS could not make the determination that a quota of 20 was sustainable.
There have been few – too few – new imports permitted into the US over the past two decades. Conservation Force was able to establish import of Cameroon elephant in 1995 and again in 1997 but not since. Import of Botswana elephant was accepted without fanfare, which was rather exceptional. USFWS insists upon remaking its findings on Tanzania imports annually, but for years has not been able to find the capacity or schedule to do it before the season was over. This year I flew into Washington, DC, with the Director of Wildlife Department, the Director of Research and the Director of the Mweka College of African Wildlife Management: the three highest management officials in Tanzania if not all of Africa. It was a substantial undertaking, but we finally got USFWS to issue Tanzania elephant trophy imports on time. (It can’t be disputed that Tanzania has the second largest elephant population in the world.) Conservation Force also established the import of flare-horned markhor from Pakistan’s community-based program a few years back.
Those are the only few new imports in 15 years, though we keep trying to have permitting used as a conservation tool. The effort in Zambia got serious in 2004. This small success has come at enormous effort and costs. It is a US problem, but the US is by far the largest market for safari hunting, thus the greatest potential force for conservation. Solving this problem is important. Without the hunting, there is far less conservation, if any, outside of fully protected areas. And there is little hunting without the necessary trophy import permitting.
Thanks go out to those conservation soldiers who hunted elephant in Zambia from 2005 to 2009 in support of that country’s program. Zambia’s elephant hunting is not a goal in itself. It is a tool devised for the conservation of the elephant by experts and stakeholders. There is no substitute for the conservation value of the hunting that is in turn dependent upon import permitting. Conservation Force’s goals are to put the force of hunting to work. It is a sensible, elementary course in theory. Unfortunately, there can no longer be any pretense that USFWS “treats permit applicants as conservation partners.” These imports were seven years in the making and were “forced.” Believe me, originally, the Zambia imports were not part of the USFWS agenda, and they did not want it to be on their agenda either.
Because of regulatory impediments, bureaucracy and attitude, conservation permitting and conservation hunting might be a failure. It certainly has not proven to hold the promise once envisioned. Two decades of futility leads to conclusions such as that expressed on one occasion by a foreign Minister: “John, your government is lying to you.” It is important that we don’t also lie to ourselves. It is necessary to accept the truth in order to reckon with it: Everyone does not share our conservation dreams and hopes. That puts the future of the resources in more jeopardy than we originally imagined.
