Last month we briefly described Conservation Force’s Request for Reconsideration
of the Tanzania import permits that had been denied. This month, we contended with the interim suspension of imports from Zimbabwe by filing an extensive, comprehensive opposition to the Federal Register Notice of the “Interim Suspension….” The formal notice in the Federal Register gave this opportunity, so we made use of it. Unlike Tanzania’s elephant, which are on Appendix I and therefore require an actual import permit, the denial of which can and must be administratively appealed before the Agency, USFWS, Zimbabwe elephant have long ago been downlisted to Appendix II for certain specified purposes, including trophy hunting. No import permit is required for Appendix II species, so we have had to devise some other means to get our information collection into the USFWS record. That is our “Comments Opposing the Interim Suspension of Imports of Elephant Trophies from Zimbabwe, 79 FR 2686 (May 12, 2014).” We filed the comment on June 6th. It is 22 pages in length with a six-page index of the 98 attached documents. It can be viewed on Conservation Force’s website at http://www.conservationforce.org/news.html
. Perhaps the conclusion will summarize what it states for readers: A great deal of information has been provided to FWS since the April 4 press release announcing the trophy import suspension and the May 12, 2014 Federal Register Notice. That information demonstrates the benefits/enhancement of safari elephant hunting in Zimbabwe. This hunting provides the largest share of the revenue for the operating budget of ZimParks (all ZimPark’s budget comes from tourist hunting revenue and donations). It provides the largest share of the revenue from the long-standing CAMPFIRE program (90% from tourist hunting and 70% from elephant hunting) with its 770,000 households (more than a million people), that has doubled and tripled the elephant in those districts. This hunting is essential to the survival of the thousands of stable or increasing elephant in important private conservancies such as Savé and Bubye Valley Conservancies. Like CAMPFIRE, neither the elephant nor the institutions would exist but for the supporting elephant tourist safari hunting revenue and incentives. The hunting and hunting-dependent operators, conservancies, CAMPFIRE, and ZimParks are the first line of defense against poaching. That capacity and value-adding effect arises from the hunting.
The quota is negligible when compared to the number of elephant that owe and depend upon safari hunting for their existence and protection. In survey after survey, elephant generally outnumber all other species in Zimbabwe. Zimbabwe has the second or third largest elephant population in the world because of the force of the regulated hunting. If the local authorities and people think there are too many elephant before the FWS import ban, there will be even less tolerance if the ban is not lifted.
Regardless of FWS’s preliminary enhancement determination, Conservation Force and other commenters, most particularly Shikar Safari Club International, pledge to fund reasonable remedial action that FWS deems necessary. Please consult us as necessary. Every benefit enumerated will be converted to a loss if US imports are not restored before institutional collapse. The benefits and necessary confidence will also be lessened in proportion to the duration of the suspension.
With this comment, we have now given the USFWS the information they lacked and needed to make an enhancement finding under the ESA. The whole country is in line for survey this year and Conservation Force and Shikar have guaranteed to bear the costs of a workshop to update the country’s National Management Plan. There is no need for further delay, though USFWS may no doubt send a second round of questions to Zimbabwe authorities for clarification of the answers they have already provided.
Already Conservation Force is planning a Supplement to the comment it filed on June 6th. We will not stop until the suspension is lifted.