Secretary of the Interior Ryan Zinke is
a sportsman who understands
On May 5, Conservation Force sent a three-page letter to Secretary of the Interior Ryan Zinke. We requested that Secretary Zinke "urgently" direct the US Fish & Wildlife Service (FWS) to approve all pending import permit applications for lion trophies from Mozambique, Namibia, Tanzania, Zambia and Zimbabwe, and all pending import permit applications for elephant trophies from Tanzania, Zambia and Zimbabwe. We pointed out that lion import applications have been pending since January 2016. And we explained how the FWS' processing delay is inexcusable, irresponsible and detrimental to these species.
Our letter detailed our interactions with the International Affairs section of FWS about these applications. For lion, we explained how the FWS has not responded to the range states, despite promising them feedback on information they submitted during the CoP17 in October. Without feedback the range countries do not know what to do or, if necessary, how to reform their practices to comply with the nebulous enhancement requirement. For elephant, Tanzania and Zimbabwe have each responded to multiple FWS information requests. Zimbabwe has responded at least five times! And yet, the FWS has not made an enhancement finding for Zimbabwe since March 2015-over two years ago. It has not made any finding for Tanzania since July 2015. The FWS has also not made an enhancement evaluation for elephant imports from Zambia, despite telling us twice that they were going to do so. (They emailed us before the CITES CoP, then told us during the CoP they would make a finding right after.) The FWS has offered no explanation for its lack of action. It has gone silent about these permits.
As we explained to Secretary Zinke, FWS enhancement permitting can be used as a tool for good. But the FWS' failure to issue import permits damages the species' recovery by denying lion and elephant the "enhancement" benefits from conservation hunting. And we submitted more than enough evidence of these benefits to sustain positive enhancement findings. Among other things, we provided data that individual operators in Zimbabwe spent between $100,000 and $500,000 annually on anti-poaching and shared over $1 million with rural communities over three years. We provided a study of 27 hunting operators in Tanzania documenting $9.8 million in habitat security, anti-poaching, and community investment in the 2013-2015 period, over-and-above fees paid to the government. We provided operator reports from Zambia evidencing contributions of over $350,000 in anti-poaching and community support in one year alone. We submitted primary documents (receipts, letters, certifications) to back up these reports. And we cited information in the range states' non-detriment findings and responses to FWS questionnaires proving that lion and elephant off-takes are limited and sustainable, and the funding from licensed, regulated hunting is dedicated to conservation purposes.
By not engaging with this data and sitting on permit applications, the FWS has shut down the flow of American hunters to these countries. Their wildlife authorities used to rely upon US revenue, but that funding is greatly reduced. The most dedicated and invested hunting operators used to count primarily on American clients. The decline in the US market is driving these operators out of business. They do not have the revenue to sustain expensive anti-poaching and community support programs. The FWS' delay has a real, detrimental impact. It is causing operators to surrender concessions, pull out of communal areas, or reduce enforcement expenditures. Unfortunately, the wildlife will suffer most. These returned concessions and reduced anti-poaching patrols will allow conversion of key habitat to agriculture and grazing. The administrative delay in issuing permits is damaging the conservation systems of these range states to the detriment of lion, elephant, and other species. As we explained to the Secretary of the Interior, this result is contrary to the ESA's intent or the goal of enhancement permitting.
We hand-delivered a copy of our letter to the Deputy Assistant Secretary for Fish, Wildlife and Parks. We have circulated it broadly among some of our key supporters. At this point, we can only hope the Secretary will heed and respond to our concerns, and grant the pending permits.