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Letter to U.S. Fish and Wildlife Service regarding proposed changes to the U.S. Endangered Species Act (ESA)Amboseli Elephant Research Project Box
15135 Langata
00509 10 November 2003 Division of
Conservation and Classification U.S. Fish and Wildlife
Service Arlington Square
Building 4401 North Fairfax
Drive, Suite 420 Arlington, VA 22203 U.S.A. Re:
Revisions to the Regulations Applicable to Permits
Issued under the Endangered Species Act,
Department of the Interior, Fish and Wildlife Service,
Federal Register, vol.68, No.175, pp53327-53334 (Sept. 10. 2003). Dear
Sir We,
the members of the Amboseli Elephant Research Project, wish to express our deep
concern over the proposed Revisions to the Regulations for importation of
endangered species into the United States, as governed by the Endangered Species
Act. We bring to this debate more than three decades of African elephant
research and management experience, in sum over 200 person years. The
proposed Revisions aim to provide financial incentives to the host countries for
“enhancement initiatives by landowners, natural resource agencies, and
others” (Summary, p.53327) through the commercial import of live animals or
the products of their consumptive use. They are styled as a logical extension of
the principle of wildlife conservation through sustainable use. However,
in our considered opinion, the Revisions do not represent a gradual evolution of
policy as much as a radical shift in emphasis away from the precautionary
principle, which is more appropriate for wildlife species endangered with
extinction, and which informs the spirit of the original ESA. The Revisions
appear to be a reckless push towards an experiment in globalized commerce for
the benefit of a very few. The
central premise of the Revisions is that placing a monetary value on wild
animals will ensure the survival of their populations and habitats. This
assertion may sound convincing, but in fact it is hypothetical, simplistic and
as yet largely untested with reliable data. There are remarkably few documented
examples worldwide, in which the “harvesting” of wild animals and plants has
proven biologically sustainable in the medium to long term. Nor are there any
examples to our knowledge where such “take” has competed successfully with
established rural land uses such as livestock production, diversified
agriculture or tourism enterprises based on wildlife viewing. Finally, we
challenge the view that the localized revenues have provided or could ever
provide significant and sufficient funding for sustainable conservation
programs. In
contrast there is a long list of species that have become endangered
specifically through unsustainable offtake and international trade (both legal
and illegal), with growing numbers listed on CITES appendices. Indeed
the threat posed by unsustainable trade was one of the original reasons for the
passage of the ESA. To encourage an expansion of international trade in species
that are already endangered seems irresponsible in the extreme. The
fact that there is now a high demand in the US for many of these endangered
species does not automatically justify the commerce. Opening the door to many
forms of trade in these species is unlikely to meet the demand; rather, it is
more likely to stimulate consumer interest and thus increase the pressure to
satisfy the appetite for wildlife products. It is simply not possible to
increase sustainable production beyond the ability of wild populations to
reproduce, particularly for large mammals such as elephants that have an
intrinsically low increase rate. The only way to meet high or growing demand for
such species is to overexploit, and even if official quotas are set for long
term conservation, unofficial channels will be found for meeting consumer
demands in the immediate term. There
is already a huge illegal trafficking in wildlife commodities and live animals
for the pet trade and private collectors. It is well-established that a limited
legal trade has provided cover for a considerably larger illicit trade in many
wildlife species, often with the collusion of government officials. This was the
clearly the case in the 1970s and 1980s when the illegal ivory trade raged out
of control across most of Africa, alongside a completely inadequate legal quota
system. Recent studies indicate that in Africa at least, failures in sustainable
wildlife conservation management are directly linked to the degree of corruption
prevalent. Many of the countries
that would be significant suppliers under the Revisions are amongst the
world’s most corrupt: the influx of short-term opportunistic funds are very
unlikely to find their way into the budget of an honest conservation
practitioner. The
likely biological and humanitarian impacts on the remaining populations by the
removal of animals for trophies, captive breeding or manufactured products are
not addressed by the proposed Revisions. In the case of the importation of Asian
elephants to supplement the dwindling American zoo “population”, the
humanitarian issues also apply to the animals “taken” from endangered wild
populations to live in the clearly unsuitable conditions of captivity, and on
the evaluation of these problems the Revisions prove no guidance. The
proposed Revisions indicate only limited responsibility on the FWS to determine
the validity of the case for import, requiring no EIA and instead only
statements in an application claiming expected benefits “for enhancement of
survival of a species” (Clause 17.22 (a)(2)(i), p.53333).
The terms of the Revisions are silent on an impartial and authoritative
mechanism to support the veracity and credibility of such statements.
In
Africa, for example, the bodies responsible for wildlife conservation, in both
government and private sector, often lack the capacity to monitor and enforce
effective conservation plans. The recent case of the importation of 11
elephants from Swaziland provides a cogent illustration of this problem, when
the FWS simply approved the permit application without requiring from the
Swaziland authorities a clear management plan or any evidence of how and whether
funds would be spent effectively on elephant conservation. The
Revisions gloss over the complexity of issues facing wildlife conservation in
the ecological and political landscapes of developing countries. Encouraging
commerce to provide money for piecemeal “enhancement initiatives” will
certainly not solve problems that in reality require a coordinated approach to
land use planning at regional, national and local levels. It is this latter form
of comprehensive approach that is most likely to yield sustainable conservation
and should be supported by the FWS. Indeed through its international grant
programs, the FWS does support many such initiatives and it is therefore
puzzling that it should seek to undermine these efforts by advocating a
high-risk commercial approach. Many
countries look to the United States, and the precedent set by the proposed
Revisions will inevitably lead other countries to adopt similar measures. This
additive effect will compound the pressure on wild populations, and thus on the
enforcement budgets of developing countries. This result will have the opposite
effect to that being espoused for increased trade. In
summary, we believe that the proposed Revisions are misguided and bound in the
long run to be deleterious for the conservation of endangered species. They do
not represent a progressive change, but a step backwards. If they are adopted,
they will lead to greater, not lesser, endangerment of many wildlife species and
will require subsequent reversal through costly remediation efforts. In the
interim, much possibly irreversible damage will be done to the cause of wildlife
conservation. We
feel that greater consultation across the spectrum of wildlife conservation
opinion, and indeed the general public, should inform your development of policy
and regulations. We ask that our concerns be considered, along with those of
other stakeholders, in your decision on how and whether to proceed with the
Revisions to the Regulations that have been proposed. Yours
sincerely Cynthia
Moss Joyce
Poole Harvey
Croze Keith
Lindsay Phyllis
C. Lee |
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