The US Fish & Wildlife Service has finally processed seven test import permits that Conservation Force filed for black-faced impala trophy imports from Namibia. The permits were denied, but with a silver lining in the denials that is very promising. Below, is a brief history of these permits and a rundown on the positive and negative significance of this development.
After years of preparatory work and pro bono legal services, Conservation Force filed seven trophy import permits for black-faced impala taken, or to be taken, in Namibia. Each of the hunters contributed, or pledged to contribute, $500 exclusively to be spent on black-faced impala enhancement in Namibia. Those import permit applicants that had already taken a black-faced impala actually paid the $500 US, and those who wanted to take one promised to pay the $500 US. Conservation Force initiated the whole effort and provided free legal representation for each applicant. Conservation Force is a member of the Black-Faced Impala Committee of the Namibian Professional Hunters Association and independently contributes to every black faced impala conservation effort in Namibia. Moreover, Conservation Force, the import permit applicants and the Namibian Professional Hunters Association have collectively funded a draft up-to-date management plan for the black-faced impala (note the importance of this below).
The permit applications were based on three alternative basis. First, under the enhancement clause of the Endangered Species Act (ESA), because of the many ways that black faced impala survival depends upon and has been furthered by tourist hunters. Second, under a regulatory provision that expressly provides that culling of captive-bred listed species for ordinary management purposes such as population control legally constitutes "enhancement". Third, under the bontebok exception in South Africa. Bontebok are captive-bred, "endangered-listed" game species pursued by the hunting community much like the black-faced impala.
Though verbally we were assured that the permits looked promising, concern grew with the passage of time. Shortly before the last presidential election, we filed a Freedom of Information Act Request as a reality check to see what was done versus what was being said. What we learned was that nothing had been done whatsoever to begin the processing of the permits. We have been on the Service’s case ever since to grant or deny the permits but, regardless, to get on with it. If the Service was not satisfied, we needed to know the particulars. On the other hand, we were not going to wait forever.
One of the silver linings in the denials is, the Fish and Wildlife Service has specified the reasons for its denial, which is what we needed to proceed. The Permit Office of the Division of Management Authority has given one primary reason for denying the permits. They want Namibia to have an up-to-date management plan, and they want that plan to properly address the threats to the species from hybridization with common impala. Although the denials did not address, point for point, all of the experts’ opinions that the ESA itself was causing the hybridization between black-faced impala and common impala, it did ironically recognize hybridization as being so significant that the failure to deal with it in a management plan was reason to deny the permits. I hope the reader is following this "Catch-22". The ESA is causing the hybridization because pure-bred impala trophies can’t be imported but Namibia must deal with that before the ESA will permit the imports.
The silver lining is the fact that the authorities and Conservation Force have already completed a draft management plan, which prominently addresses the very issues the Service specifies it would like to see addressed before granting permits. The way seems clear to finish this successfully.
We are appealing the denials because of the important principals involved that go beyond the scope of this article. We will also continue Conservation Force’s Black-Faced Impala Initiative by re-submitting the existing permit applications when the draft plan is completed. The smart expenditure of the $500 "enhancement" contributions from the hunters will also continue the NAPHA Black Faced Impala Committee work and the submission of new black-faced impala applications should all help. We will continue our free representation until the job is done.
There is much more to this. We have a great deal of concern for the arms-lengths way the Service has handled the applications. Conservation Force’s objective is to use hunting as a force for conservation of listed game species. The Service has made no effort to partner, pursuant to its proposed new conservation partnership policy, nor has it cooperated for the conservation of these species pursuant to the Executive Order of the President demonstrated at the recent White House Cooperative Conservation Conference. We were given no information beforehand that the permits were to be denied, nor were we told why they were to be denied. If there was any correspondence with Namibia, we were not told of it, or included in it. It’s time for a change. We are working on better partnering, too. This is just some of the many things Conservation Force is doing for you.
The only "endangered-listed" game species import permits that have been issued in the history of the ESA have been those for bontebok taken in South Africa. Bontebok survival has been advanced by managed captive breeding, culling of surplus males and related revenue from tourist hunting by Americans just like the black-faced impala of Namibia. We cited that fact as reason, or precedent, for approval of the seven black-faced impala permits. In its denial of the black-faced impala permits, the Service distinguishes the bontebok by pointing out that South Africa had an up-to-date management plan in effect that expressly addresses the threat of hybridization, which Namibia does not yet formally have for black-faced impala. Once again, the draft plan in Namibia for black-faced impala that the hunting industry and black-faced impala owners/breeders and ministry have been developing will close that gap.
Another parallel to the bontebok and now the black-faced impala, is the hunting of black rhino in South Africa and Namibia. Black rhino numbers in both countries are roughly equivalent in numbers to bontebok and also black-faced impala. The strategy behind the black rhino conservation has been to build up the captive population in appropriate protected areas, then to translocate the surpluses for captive breeding to private stakeholders. This is basically the same strategy used for the white rhino (not ESA-listed), bontebok (ESA-listed as "endangered"), and black-faced impala (also ESA-listed as "endangered"). Perhaps you can see the importance and relationships of all that Conservation Force is doing. What you see explained here and in monthly issues of World Conservation Force Bulletin over the past nine years is only a portion of what we do for the hunting community.
