By John J. Jackson, III and Regina Lennox
On August 30, the US Fish & Wildlife Service (FWS) finally updated its enhancement finding for the import of wild and wild-managed lion trophies from South Africa. This action builds on the October 2016 positive finding for 2016 announced in the media by former Director Dan Ashe. This August 2017 positive finding authorizes the import of wild and wild-managed lion trophies hunted in the 2017 through 2019 seasons-the period covered by South Africa's current Biodiversity Management Plan for the lion (2015-2019).
In making this finding, FWS set out to evaluate the "overall conservation and management of the species in the country" and "whether that … addresses the three primary threats to the species … [of] habitat loss, loss of prey base, and human-lion conflict." FWS pledged to "work closely with the range countries and interested parties to obtain information." The required information includes population levels and trends; quotas; the species' "biological needs"; reinvestment of hunting fees in conservation; management practices; legal protection of the species; and "local community involvement." FWS received several documents from South Africa's Department of Environmental Affairs (DEA), met and communicated with the DEA, and received some information from other persons/entities, including Conservation Force. We have also reviewed all FWS-DEA email correspondence concerning lion imports.
After considering the information received from South Africa and other sources, the finding determines that South Africa's lion population is stable or increasing. The wild lion population is approximately 2,200. Almost all of the wild lion habitat is in national parks and is not hunted. South Africa's wild-managed lion population is approximately 800. It is fragmented across 45 fenced reserves, each less than 1,000 km2. These lion are to be managed as a meta-population, under a plan that mimics natural ecological functions. Among other things, the meta-population plan will provide for greater genetic exchange and the mimicking of natural processes like dispersal and emigration. Under this plan, wild-managed lion may be hunted as a management action and subject to a licensing system that approves offtakes case-by-case. These trophies will be importable once the evolving meta-population plan is in place.
The FWS' positive enhancement finding also concludes that South Africa's management of wild and wild-managed lions benefits the species by mitigating its three primary threats (see above). According to the finding, wildlife ranching in South Africa and the fencing of individual protected areas has minimized habitat and prey base loss and human-lion conflicts. Revenues from regulated hunting are a key incentive for wildlife ranchers. And US hunters are a key component of the hunting industry.
Four private reserves in South Africa have been listed as having wild lion populations. FWS has issued permits for trophies from two of them so far.
According to the finding:
Based on the information available to the Service, the presence of private reserves has increased the number and diversity of wildlife in South Africa, thus fueling the hunting industry, which funds the ongoing success of private reserves. It appears that without the hunting industry, these reserves, which have become islands of wilderness in a sea of civilization in much of South Africa, would not be economically viable, and therefore would not exist. With an annual harvest of historically 10 wild-managed lions and two wild lions annually, US hunter participation in lion hunts, in and of its own, is not enough to make or break the industry and lead to the decline of reserves.
However, US hunters do play a significant role in the industry and the removal of their participation could have a long-term impact….
Thus, to preserve these benefits for the species (and subject to continued regulation of offtakes), FWS approved the import of wild and wild-managed lion trophies. The finding recognizes the "direct and indirect" benefits for the lion and confirms the essential role well-managed and monitored lion hunting plays in South Africa's wildlife conservation and management.
Although this positive finding is welcome news, it must be taken in context. The number of wild and wild-managed lion trophy imports from South Africa is negligible-approximately two wild and 10 wild-managed per year. Prior to the listing, most lion trophy imports from South Africa were captive-bred. FWS made a negative 2016 finding for import of captive-bred trophies because it had no information that captive-bred lion hunting enhances the survival of the species in the wild. That finding has not yet been updated and is being treated separately from wild and wild-managed. Conservation Force also has not submitted any import application for captive bred lion and has no present plan to do so.
Moreover, the number of imports is even more limited because FWS is not yet issuing import permits for wild-managed lion trophies. The DEA provided a list of properties having wild lion to the FWS, and requested that only imports from these properties be approved. The FWS is honoring this request. (FWS emails confirm that the FWS is running properties by the DEA before issuing permits.) None of the properties on the DEA's list have wild-managed
In part, properties with wild-managed lion are not yet on this list because South Africa's Scientific Authority is currently evaluating individual properties to confirm they actually maintain wild or wild-managed lion, and not captive-bred lion in disguise. But even for properties that have been confirmed to have wild-managed lion by the Scientific Authority, the DEA has requested FWS not currently approve imports. The DEA is waiting until the meta-population management plan is completed. Therefore, while the positive enhancement finding authorizes imports of wild-managed lion trophies, it is unlikely FWS will issue import permits for these lion until the DEA gives the green light.
In short, apparently FWS is approving imports from South Africa in three stages-at the country level, the source level (wild/wild-managed v. captive-bred), and the property level. According to the finding, "the Service will review each application for import of such specimens on a case-by-case basis…" This may be a unique situation for South Africa due to the prevalence of captive-bred lion. But it is possible FWS may issue permits for other countries on a property or operator level as well. If so, the information Conservation Force collected from operators in Tanzania, Zambia and Zimbabwe will be crucial to FWS' decision-making.
Under this case-by-case review, FWS has issued approximately six wild lion import permits for 2017: four for hunts in the Kalahari Oryx Private Game Reserve and two for hunts in the Khamab Kalahari Reserve. We do not know of permits being issued yet for the other two "wild" lion areas approved by DEA and FWS (see areas listed on map). FWS should issue permits for wild-managed lion trophies as soon as South Africa implements the meta-population management plan and the DEA provides a list of approved properties having wild-managed lion. Although we do not know how soon the meta-population management plan will be completed, we know the DEA is actively working on it. For the time being, however, the number of exports from South Africa may be as low as four to six wild lion trophies per year.