By the time you read this, the new rule for these three endangered-listed species will be in effect, April 4, 2012. Conservation Force has and continues to contribute its expertise and assistance to help ranches make the transition.
Though the date has passed, that date was just the date the special regulations were made effective, not a deadline to apply for permits. A ranch owner/operator can apply for the permits at any time. The importance of the date of April 4 is that a ranch must now have a captive-bred permit (technically a registration of the ranch/facility) to trade any of the three species interstate or to get a take permit. You also need a take permit, second permit, as well to harvest the animals whether recreationally or for profit. A captive-bred permit/registration is sufficient for the rancher or staff to do necessary culling, but not for third parties, whether family, friends or paying customers. You don’t need a captive-bred permit/registration to trade state-to-state if it is not a commercial transaction, but we are not clear just what that transaction might be, so we advise obtaining a permit to protect yourself.
The inclusion of these three listed species under the long-existing ESA two-permit system has brought about noteworthy changes in how the system is administered, some good and some perhaps not so good.
First, the Service has temporarily shifted four persons to handle the anticipated applications rush on a priority basis. Though that is good, it may be the cause of new nuisances in the administration of this special permitting. One such change is a soft requirement that the enhancement contribution to an in situ project in a country of origin be 10 percent or more of the gross sales price of each animal taken, i.e. 10 percent of the price must be sent to a project that enhances the species’ survival in the wild. There has never before been a minimum, but now the Chief of Permits requires 10 percent or more unless less can be justified. We will have to wait to see how that plays out, but we have advised all those we have assisted that there is now a minimum.
Due to a request from Dallas Safari Club, Exotic Wildlife Association and Conservation Force, the Service has beefed up its pitiful instructions that appear on the back of the permit application forms. The Service has issued Guidelines that are much more useful. They are not in the Instructions on the back side of the permit applications because that takes years to reform. The Guidelines are on the Service’s website and can be found on Conservation Force’s website at http://www.conservationforce.org/pdf/3%20Amigos%20Guidelines.pdf. Many of the questions are intended for zoos and circuses, not open ranches, so those questions can truly discourage a permit applicant from a ranch. It still takes some experience to properly complete the application. Dallas Safari Club and FWS co-hosted a workshop in Kerrville, Texas, to help many applicants with their permits, and we continue to help others as a public service. Conservation Force played a role in developing these guidelines and is proud of it. It is a positive development.
Some permit applications have been returned and delayed because of a need for photographs better depicting cover on the habitat. In those instances, satellite photographs just did not satisfy the FWS’ requirements.
Small put-and-take or churning ranches that are disposing of surplus animals from other ranches may not be permitted. The nuisances and restrictions on those, if permitted at all, are yet to be worked out.
Conservation Force has been helping applicants and answering inquiries; up to 10 or more a day for months. We have not been able to keep up with the demand to our satisfaction because we did not have the resources to beef up our staff to meet the crisis in a timely manner. Nevertheless, we have maintained our leadership and will continue to serve this niche of the industry and enhance the survival of these species in projects that already exist and to initiate others. Our memberships on the Antelope and Deer Specialist Groups of IUCN will be helpful. Remember that the anti-hunting organizations track down the conservation projects supported by hunting ranches and intimidate the project partners and managers. Their aim is to kill the project or have it reject the revenue from the permits (10 percent per animal) so that the dependent ranch permits can’t be issued or renewed. We have always been able to stay ahead of these attacks and threats but welcome any suggestion on the conservation of these three species. Hunters are the force. (Humane Society International, HIS, made the most recent attack. It receives nearly two million dollars a year from HSUS, according to HSUS’ recent 990 tax form.)
A special thanks goes to Dallas Safari Club, Texas Wildlife Association, Houston Safari Club, the Conklin Foundation and Ricardo Longoria for their support.
