In April, US Fish & Wildlife Service (USFWS) published the positions it is considering for the next CITES Conference of the Parties, CoP16 in Thailand, March 3-15, 2013. If the US is to propose anything at this late point in time, CITES Resolutions require that its proposal be related to a species for which the US is a range country. The US is a range country of the polar bear.
The USFWS announced it was not likely to make a proposal to uplist narwhal and white rhinoceros (though it did not specify the time had passed for rhino since the US is not a range nation of rhino). The African lion was not on the menu at all, so now any such proposal is up to African range countries. That deadline is early October. A species of interest to readers that is still under consideration (“undecided”) is the polar bear, which had been suggested for uplisting to Appendix I by the International Fund for Animal Welfare, the Species Survival Network and the Center for Biological Diversity. A transfer to Appendix I would end all commercial trade of polar bear, which would have the greatest impact on Canada. It would also add another barrier against US trophy imports. Canada is said to be the only country with commercial trade, but unsaid is the Alaskan native trade that is commonly overlooked. An uplisting would act as a bar on Alaskan native trade as well because all commercial trade is barred for Appendix I species.
Of course, Conservation Force and its partners filed an extensive opposition to any such proposal by the United States with itemized reasoning. The comment filed by WWF-TRAFFIC is particularly worthy of note and may surprise readers. An excerpt of that jewel follows:
Polar Bear (Ursus maritimus)
WWF and TRAFFIC cannot support the transfer of Polar bear (Ursus maritimus) from CITES Appendix II to Appendix I for the following reasons:
• WWF and TRAFFIC support the principle that, having adopted criteria for listing species on Appendices I and II, the CITES Parties should adhere to them. Not to do so would be to jeopardize the listing of those species that clearly do meet the criteria, and are in urgent need of listing.
• The polar bear does not meet any of the biological criteria for inclusion in Appendix I as established in Annex 5 to Resolution Conf. 9.24 (rev CoP14). An estimated 20,000-25,000 polar bears currently range through Canada, Greenland, Norway, Russia and the US. The global population of polar bears is therefore not small and furthermore, the global population has not undergone a marked decline in the recent past and the species’ area of distribution is not restricted.
• WWF and TRAFFIC would note that the IUCN Polar Bear Specialist Group (PBSG) is conducting an assessment of the global polar bear population at this time. This assessment is not expected to be concluded prior to the October deadline for the submission of CITES listing proposals; it would be prudent to await the outcome of this assessment prior to taking another Appendix I proposal forward.
• The main threat to polar bears is the retreat of sea-ice habitat driven by global warming. While climate change and the subsequent impacts on polar bears will occur at different rates and times across the Arctic, the current lack of action to reign in CO2 emissions will ultimately threaten polar bears globally. The loss of sea ice habitat (which polar bears depend on for feeding, traveling, and mating) associated with rapid climate warming is a significant and ongoing threat to the conservation of the species.
• Additional threats to the species include industrial development (such as offshore oil and gas, shipping and mining), toxic pollution and conflict with humans.
• CITES criteria are based on consideration of past declines and not projections far into the future. At CoP13, Parties voted to remove from the criteria a provision whereby a species could be listed on Appendix I if it was thought likely to meet the criteria within five years. The rationale for this decision was that such a provision was unnecessary, since the CoP meets approximately every three years. It would, therefore, be incongruous if Parties were to include the polar bear on Appendix I on the basis of a population decline that is predicted to take place over a 50-year period into the future.
• Trade is not a significant threat to the species. Canada is the only country that currently allows commercial exports of polar bear parts and products – all of which result from quotas provided for Aboriginal subsistence hunting. Between 1999 and 2008, an average of 292 Canadian polar bears (2% of the population) entered international trade on an annual basis.
• An Appendix I listing would be unlikely to reduce the number of bears hunted in any range state.
• Since the last CoP, issues have arisen around the viability of harvest levels in three (all within or shared by Canada) of the world’s 19 management units. Exports of polar bear parts from these management units are already set at zero, or very low, and therefore an Appendix I listing is extremely unlikely to alter the situation. Regional and federal authorities in Canada are also in the process of updating population estimates for all three units as part of the process to evaluate quotas. Rather than listing the species on CITES Appendix I, WWF and TRAFFIC supports maintaining polar bears on CITES Appendix II, and would encourage the US and all range states to ensure that harvest is not detrimental to the long-term viability of the species.
The USFWS notice calling for comments on this possible proposal had a rather puzzling justification. It cited its earlier (CoP15) determination that the polar bear meets the biological and trade criteria for inclusion on Appendix I as a standing fact, even though it was wholly rejected at CoP15. It also points out that the “Government of Canada in November 2011 declared that the polar bear in that country was a ‘species of concern’ under the Species at Risk Act” and that “as a result…Canada…must prepare within three years a management plan….” These precautions and protective measures by Canada are additional reasons not to uplist the bear, not vice versa. Where will this doubletalk stop? This is a very embarrassing way to treat our good neighbors and can also end-round the Congressional protection intended for Alaskan Native sale of subsistence hand-crafted art and clothing of bear parts. Contradictorily, the USFWS has recently confirmed the important “intrinsic role” that native subsistence trade “play(s) in the conservation of marine mammals.” Special Rule for the Polar Bear, 77 FR 23422 at 23444 through 23445, April 19, 2012.
