With recognition to SCI Hunters Advocacy
On June 2, 2016, the U.S. Fish and Wildlife Service (FWS) announced a final rule imposing a ban on essentially all commercial trade of ivory. Although the newly revised law does not prohibit the importation of legally hunted elephant trophies into the U.S., it does impose some new requirements and restrictions. Beginning July 6, 2016, every individual seeking to import a legally hunted African elephant into the United States will be required to obtain an Endangered Species Act permit to do so. Although for decades the FWS has mandated findings that the importation of African elephants enhances the survival of the species, permits were not previously required for the importation of elephants from countries where the populations are listed on Appendix II of CITES (i.e. Namibia, South Africa, Zimbabwe and Botswana). Going forward, all African elephants, regardless of their CITES Appendix listing status, will require ESA permits for importation into the United States. The FWS insists that the permit requirement will not have a major impact on trophy importation. “Issuance of a permit confirming that an enhancement determination has been made is unlikely to result in any fundamental change in how trophies are treated upon import.”
Although the rule imposes additional conditions on the importation of legally hunted trophies, the rule does contain significant language, such as the quote below, about the benefits of well-regulated elephant hunting.
We continue to believe that well-managed trophy hunting can benefit conservation and disagree that there is little basis for this assertion. Trophy hunting can generate funds to be used for conservation, including for habitat protection, population monitoring, wildlife management programs, and law enforcement efforts. The IUCN Guiding Principles on Trophy Hunting as a Tool for Creating Conservation Incentives (Ver.1.0, August 2012) state that well-managed trophy hunting can “assist in furthering conservation objectives by creating the revenue and economic incentives for the management and conservation of the target species and its habitat, as well as supporting local livelihoods” and, further, that well-managed trophy hunting is “often a higher value, lower impact land use than alternatives such as agriculture or tourism.” When a trophy hunting program incorporates the following Guiding Principles, IUCN considers that trophy hunting can serve as a conservation tool: biological sustainability; net conservation benefit; socio-economic-cultural benefit; adaptive management-planning, monitoring, and reporting; and accountable and effective governance. We support this approach.
In addition to the permit requirement, the new rule imposes a limit of two elephant trophies per hunter per year. The FWS explained that the intent of the restriction is to prohibit individuals who participate in elephant population management culls from engaging in commercial trade in the ivory from elephants taken in those culls.
SCI opposed these restrictions in comments we submitted when the FWS proposed the new rule. The imposition of a permit requirement adds an unnecessary burden for hunters and gives the FWS additional opportunities to deny importation to individuals who legally hunt African elephants abroad. We will monitor the FWS’s application of the new rule to gauge how SCI members and others in the hunting community are affected, as well as if and how these new requirements benefit or harm elephant conservation and anti-poaching efforts in Africa.