On December 5, 2013 the US Fish & Wildlife Service (USFWS) noticed a “revision” of its proposal to downlist the straight-horned markhor to “threatened” status with a special rule for trophy imports. The proposal now includes the Kabul markhor (Capra falconeri megaceros)
as a member of the subspecies to be downlisted from endangered to threatened under the ESA with a special rule, 78 FR 73173. This revision broadens the number of populations and areas of markhor to be downlisted to threatened under the ESA.
We propose to combine the straight-horned markhor (Capra falconeri jerdoni) and the Kabul markhor (Capra falconeri megaceros) into one subspecies, the straight-horned markhor (Capra falconeri megaceros), under the Endangered Species Act…. We are also proposing a concurrent special rule. The effects of these regulations will be to protect and conserve the straight-horned markhor, while encouraging local communities to conserve additional populations of the straight-horned markhor through sustainable-use management programs.
Upon downlisting, the revised proposal would not immediately permit import of the Kabul markhor; not until the particular population is qualified like the Suleiman markhor in the Torghar area of Pakistan. This is desirable because it will motivate additional authorities and local people to follow the successful hunting-dependent model of the Torghar area to capture a piece of the US tourist hunting market – the largest in the world. This is the combined purpose and anticipated result of the downlisting and special rule. In effect, the USFWS is creating a tool to reward conservation practices that benefit threatened species to be used in lieu of “enhancement permits” under the ESA. If administered forthrightly, it can prove to be an additional tool to recover listed game species. After all, their status as a game species should be an added force for their recovery.
The revised proposal can also be found on Conservation Force’s website at www.conservationforce.org/news.html. Comments on the broadened proposal must be received on or before February 3, 2014. Commenters from both sides of the issue felt that the subspecies included the Kabul. No one is stating that the status of the Kabul warranted their downlisting, just that they should be included because of nomenclature.
We are hoping that the USFWS doesn’t take 12 full months to reach a final determination and rulemaking on the revised downlisting proposal. We are also hopeful that the broadened proposal does not serve to defeat the downlisting. There is no doubt that animal rights groups raised the nomenclature issue to waylay the downlisting by adding populations not faring as well as the Suleiman in the Torghar area. Nevertheless, some respected experts also advised that the Kabul should be treated as the same subspecies. Until this is resolved, we are still in court appealing the denial of the import permits for Suleiman markhor from Torghar. See the following story in this issue regarding that appeal.